Eastern Platinum Limited (EPL)
Chrome Plant
Draft Scoping Report
19 March 2018
Alta van Dyk Environmental Consultants cc Postnet Suite # 745 Private Bag X 1007 Lyttelton 0140 Tel: +27 12 940 9457 Cell: +27 82 782 4005 [email protected]
Eastern Platinum Limited (EPL) Chrome Plant
Draft Scoping Report
19 March 2018
Project Ref - 005-032
Prepared by :
The perusal, use, copying or storing of this Report is intended for the use of the recipient. As such, the information may be legally privileged and the unauthorized use is strictly prohibited and may be unlawful.
The opinions expressed in this Report have been based on the information supplied to Alta van Dyk Environmental Consultants cc (AvDEnvironmental) by company officials. The opinions in this Report are provided in response to a specific request from company officials to do so. AvDEnvironmental has exercised all due care in reviewing the supplied information. Whilst AvDEnvironmental has compared key supplied data with expected values, the accuracy of the results and conclusions from the review are entirely reliant on the accuracy and completeness of the supplied data. AvDEnvironmental does not accept responsibility for any errors or omissions in the supplied information and does not accept any consequential liability arising from commercial decisions or actions resulting from them. Opinions presented in this report apply to the site conditions and features as they existed at the time of AvDEnvironmental’s investigations, and those reasonably foreseeable. These opinions do not necessarily apply to conditions and features that may arise after the date of this Report, about which AvDEnvironmental had no prior knowledge nor had the opportunity to evaluate.
VERSION CONTROL
Alta van Dyk Environmental cc
Author(s): Draft ______Project Director: Alta van Dyk
Approved: ______Position: Director: Environmental Legal and Technical Date: 19 March 2018
PURPOSE OF THE DOCUMENT
The scoping process is the first phase of the Environmental Impact Assessment (EIA) as required by the National Environmental Management Act (NEMA) and aims to identify significant issues and determine the scope of the subsequent Impact Assessment phase.
The scoping process culminates in the compilation of a Draft Scoping Report (DSR) (This Report) for public review, which includes a description of the environmental issues, potential impacts, potential alternatives and a detailed plan of study for the EIA phase. The scoping phase is the first phase in obtaining Environmental Authorisation from the Department of Mineral Resources (DMR) and the Department of Rural, Environment and Agricultural Development (READ) and outlines a plan for the Environmental Management Programme Report (EMPr) and EMPr consolidation.
The Scoping Report aims to: Provide an outline of the proposed project; Provides an outline of the proposed process to be followed; Identify all possible environmental impacts of the proposed project; Identify and address concerns raised by Interested and Affected Parties (I&APs) and stakeholders; Identify potential alternatives for the proposed project; and Focus on significant environmental impacts for further study in the Environmental Impact Report.
With the completion of the Scoping Phase, all comments received will be included within the Final Scoping Report and attached as a component of the Stakeholder Engagement Process. The Draft and Final Scoping Report will be submitted to the relevant authorities: Department of Mineral Resources and the North West Department of Rural, Environment and Agricultural Development (NWREAD), for comment and decision making. It should be noted that stakeholder consultation is an on-going process which continues into the EIA phase of the project.
Screening Phase
No EIA Required EIA Required
Scoping Phase We are here in Determine the scope of the EIA the process
Environmental Impact Assessment Analysis of the impacts
Determination of mitigation measures PARTICIPATION PUBLIC
Decision making
Development Not Approved Development Approved
Appeal
Implementation Environmental Management Plan Implemented
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YOUR COMMENTS ON THE DRAFT SCOPING REPORT
The Draft Scoping Report is available for a 30 day public comment period from 19 March 2018 to 23 April 2018 at the following public places:
Public Place Locality Physical Address Contact Details 317 Erf 014 572 3611 Marikana Public Library Marikana Marikana 18 Murray Avenue 012 252 3121 Brits Post Office Brits Brits Hannelie Ryan Lonmin EPL Offices Marikana EPL 014 571 2399 Matshediso Matshedi Lonmin EPL Hostels Marikana EPL 014 571 4445 Bapong Community Health Next to Bapo Primary School Bapong 012 245 1237 Centre Skoolplaas Street, Bapong Stand 0864H Segwaelane Clinic Brits 012 245 1162 Segwaelane, Brits Unit 3698 Offices of Alta van Dyk Centurion 4 Garcia Peak Road 012 940 9457 Environmental Consultants Midlands Estate Website: www.altavandykenvironmental.co.za
The methods of commenting during the public review of the Draft Scoping Report are the following: Completion of the comments sheet enclosed within the Draft Scoping Report as part of the Background Information Document (Annexure A); Additional written submissions directly to Alta van Dyk Environmental Consultants cc; and Comments by post, e-mail, fax or telephone.
DUE DATE FOR COMMENT ON THE DRAFT SCOPING REPORT WAS
23 April 2018
Comments were required to be submitted to the Project Manager:
Alta van Dyk Alta van Dyk Environmental Consultants cc Postnet Suite #745 Private Bag X 1007 Lyttelton 0140
Cell phone: +27 82 782 4005 Tel: +27 12 940 9457 Fax: +27 86 634 3967 E-mail: [email protected] [email protected] [email protected]
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Contents
1 INTRODUCTION AND BACKGROUND 1 1.1 Company Details 1 1.2 Independence of the Environmental Assessment Practitioner 2 1.3 Properties 3
2 Detailed project description 5 2.1 Existing Operations 5 2.2 Proposed New Infrastructure 6 2.3 Life of Project 6 2.4 Locality 6
3 alternatives considered 11
4 LEGISLATIVE BACKGROUND 13 4.1 The Constitution of the Republic of South Africa (Act 108 of 1996) 13 4.2 National Environmental Management Act, 1998 (Act no. 107 of 1998) and National Environmental Management Amendment Act, 2008 (Act No. 62 of 2008) (NEMA) 13 4.3 Minerals and Petroleum Resources Development Act, 2002 (Act 28 of 2002) 15 4.4 The National Environmental Management: Waste Act (Act 59 of 2008) (NEM:WA) 16 4.4.1 Waste Classification and barrier requirements 16 4.5 National Environmental Management Air Quality Act, 2008 (Act 39 of 2008) 17 4.5.1 Dust Fall-out 17 4.5.2 Regional Air Quality Management Plan 18 4.6 National Water Act, 1998 (Act 36 of 1998) 19 4.6.1 GN704 Requirements 20 4.7 Other legislation 23
5 ENVIRONMENTAL STATUS QUO 24 5.1 Topography 24 5.2 Climate 24 5.2.1 Temperature 25 5.2.2 Evaporation 26 5.3 Geology 27 5.3.1 Upper Critical Zone (UCZ) 27 5.3.3 UG2 Chromite Layer 28 5.4 Soils 28 5.4.1 Agricultural Potential 29 5.4.2 Land Use 29 5.5 Flora 30
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5.5.1 Rare, Endangered and Protected Species 31 5.5.2 Alien Invasive Species 31 5.6 Fauna 32 5.6.1 Rare and Endangered Species 32 5.7 Air Quality 32 5.8 Groundwater 33 5.9 Surface Water 33 5.9.1 Catchment Area and Characteristics 33 5.10 Heritage 36 5.11 Noise 37 5.12 Visual 37 5.13 Socio-economic 37 5.13.1 Population Density 39 5.13.2 Age and Gender Distribution 39 5.13.3 Household Income 39 5.13.4 Language 39
6 possible environmental impacts 40 6.1 Construction Phase 40 6.2 Operational Phase 40 6.3 Decommissioning and Closure Phase 40 6.4 Cumulative Impacts 41
7 Impact Assessment Methodology 42 7.1 Impact Assessment Methodology to be used 42
8 Plan of Study for Environmental Impact Assessment (EIA) 44
9 Public Participation Process 48 9.1 Notification of I&AP’s 48 9.1.1 Notification Letters 48 9.1.2 Site Notices 49 9.1.3 Newspaper Advertisement 49 9.2 Stakeholder Engagement during Scoping and EIA Phase 49
10 Conclusion 51
11 Undertaking by EAP 52
12 References 53
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Annexures
Annexure A: Stakeholder Engagement Report
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Tables
Table 1.1: Contact Details ...... 1 Table 1.2: Lonmin – Mining Authorisations ...... 2 Table 1.3: Contact Details - Environmental Practitioner ...... 3 Table 1.4: Specialist Team ...... 3 Table 1.5: Property Information ...... 4 Table 2.1: Outside Co-ordinates ...... 7 Table 3.1: Alternatives as provided through NEMA ...... 11 Table 3.2: Alternatives for the proposed new Chrome Plant ...... 11 Table 4.1: List of Activities applied for ...... 13 Table 4.2: Landfill Disposal Requirements...... 17 Table 4.4: Acceptable Dust Fall Rates ...... 18 Table 4.5: List of applicable Water Uses requiring approval ...... 20 Table 4.6: GN704 requirements ...... 20 Table 4.7: Other Legislation ...... 23 Table 5.1: Temperatures (0C) for Lonmin Platinum (2002)...... 25 Table 5.2: Long-term monthly average evaporation ...... 27 Table 5.3: Sources of pollutants NW Province and Madibeng ...... 32 Table 7.1: Scale utilised for the evaluation of the Environmental Risk Ratings ...... 42 Table 7.2: Scale utilised for the evaluation of the Environmental Risk Ratings ...... 43 Table 8.1: Terms of Reference for Specialist Studies / Plan of Study for EIA ...... 45 Table 9.1: Locations of the Draft Scoping and Draft Environmental Impact Assessment Reports ...... 49
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Figures
Figure 1:1 Mining Rights Area (SEF, 2012) 2 Figure 2.1: Regional Setting of the Lonmin Operations (Highlands Hydrology, 2012) 8 Figure 5:1 Average monthly precipitation and rainfall days for Rustenburg (World Weather Online, 2017) 24 Figure 5:2 Average monthly precipitation and rainfall days for Brits (World Weather Online, 2017) 25 Figure 5:3 Long-term monthly maximum and minimum temperatures (0C) for Rustenburg (World Weather Online, 2017) 26 Figure 5:4 Long-term monthly maximum and minimum temperatures (0C) for Brits (World Weather Online, 2017) 26 Figure 5:5 Regional Geology: Bushveld Igneous Complex 28 Figure 5:6 Quaternary Catchment Areas – A21K and A 21J 34 Figure 5:7 Quaternary Catchment Areas – A21K and A 21J 35
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GLOSSARY AND TERMINOLOGY
“alternative” a possible course of action, in place of another, that would meet the same purpose and need (of the proposal). Alternatives can refer to any of the following but are not limited to: alternative sites for development, alternative projects for a particular site, alternative site layouts, alternative designs, alternative processes and alternative materials.
“backfill” Waste material used to fill the void created by mining an orebody.
“base metal refinery” The process where precious metals are separated from base metals.
“bund” An impermeable enclosure or structure to contain spillages under or around an area where hazardous substances are stored or handled.
“concentrator” A process involving the milling, crushing and flotation of platinum ore.
“construction” means the building, erection or establishment of a facility, structure or infrastructure that is necessary for the undertaking of a listed or specified activity but excludes any modification, alteration or expansion of such a facility, structure or infrastructure and excluding the reconstruction of the same facility in the same location, with the same capacity and footprint.
“chromite” he chief ore mineral of chromium.
“closed circuit” A loop in the milling process wherein a selected portion of the product of a machine is returned to the head of the machine for finishing to required specification.
“demarcation” is defined as a limit or boundary, separating space by any form or material.
“domestic waste” Waste, excluding hazardous waste that emanates from premises that are used wholly or mainly for residential, educational, health care, sport or recreation purposes.
“domestic waste water” defined as waste water predominantly from residential and housing facilities.
“environment” The surroundings within which humans exist and that are made up of: i. the land, water and atmosphere of the earth; ii. micro-organisms, plant and animal life; iii. any part or combination of (i) and (ii) and the interrelationships among and between t them; and iv. the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being. This includes the economic, social, cultural, historical and political circumstances, conditions and objects that affect the existence and development of an individual, organism or group.
“environmental impact assessment (EIA)” An Environmental Impact Assessment (EIA) refers to the process of identifying, predicting and assessing the potential positive and negative social, economic and biophysical impacts of any proposed project, plan, programme or policy which requires authorisation of permission by law and which may significantly affect the environment. The EIA includes an evaluation of alternatives. As well as recommendations for appropriate mitigation measures for minimising or avoiding negative impacts, measures enhancing the positive aspects of the proposal and environmental management and monitoring measures.
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“environmental management plan (EMP)” An environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the construction, operation and decommissioning of a project are prevented; and that the positive benefits of the projects are enhanced.
“footprint” Refers to the surface area of land directly affected by a development or activity, and is directly related to the physical extent and size of the development or activity.
“general waste” - Waste that does not pose an immediate hazard or threat to health or to the environment, and includes— i. domestic waste; ii. building and demolition waste; iii. business waste; iv. inert waste; or v. any waste classified as non-hazardous waste in terms of the regulations made under section 69;
“hazardous substances or hazardous waste” hazardous substances are substances that are potentially dangerous and may affect human and/or environmental health. This would be because of the substances’ inherent chemical and physical composition, which could be toxic, poisonous, flammable, explosive, carcinogenic or radioactive. Hazardous substances include, but are not limited to: Human excrement, fuel, lubricating oils, hydraulic and brake fluid, acids, paints, anti- corrosives, insecticides, pesticides, detergents, cement, etc. Hazardous wastes are the by-products and wastes associated with the use of hazardous substances as well as potentially hazardous items such as spent batteries, old oil filters, light bulbs, circuit boards, sharp objects etc. which requires special collection and handling.
“interested and affected parties” Individuals, communities or groups, other than the proponent or the authorities, whose interests may be positively or negatively affected by the proposal or activity and/ or who are concerned with a proposal or activity and its consequences.
“leachable” Extractable by chemical solvents.
“leaching” A chemical process for the extraction of valuable minerals from ore; also, a natural process by which ground waters dissolve minerals, thus leaving the rock with a smaller proportion of some of the minerals than it contained originally.
“life of mine (LoM)” number of years that the operation is planning to mine and treat ore, as taken from the current mine plan.
“Lonmin Plc” A company incorporated in England under registration number 103002 and listed on the London Stock Exchange, holding an 82% shareholding in each of Western Platinum Limited and Eastern Platinum Limited.
“mining” The making of any excavation for the purpose of winning a mineral. The term covers reconnaissance, prospecting, mining or retention operations in relation to a prospecting or mining right, permit or license.
“mining related activities” Activities directly related to mining, which are required for mine construction, operation and/or rehabilitation. Such activities serve no purpose other than to support the construction, operation and/or rehabilitation of the mine, and will be ceased, removed and/or rehabilitated at the end of the life of the mine, unless they can be utilised as
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part of the end-use requirement of the mine and to the benefit of the local community and environment.
“mitigate” The implementation of practical measures to reduce adverse impacts or enhance beneficial impacts of an action.
“monitoring” The repetitive and continued observation, measurement and evaluation of environmental data, to enable the detection of changes over a time period to assess the efficiency of control, management and/or mitigation measures.
“open pit” A mine that is entirely on surface. Also referred to as open-cut or open-cast mine.
“ore” A mixture of ore minerals and gangue from which at least one of the metals can be extracted at a profit.
“ore body” A natural concentration of valuable material that can be extracted and sold at a profit.
“public participation process” A process of involving the public in order to identify issues and concerns, and obtain feedback on options and impacts associated with a proposed project, programme or development. Public Participation Process in terms of NEMA refers to: a process in which potential interested and affected parties are given an opportunity to comment on, or raise issues relevant to specific matters.
“resource” The calculated amount of material in a mineral deposit, based on limited drill information.
“run-of-mine” A term used loosely to describe ore of average grade.
“Scoping Report” - A scoping report is a report whose purpose is to describe the methodology and range of activities of the appraisal work to be done in order to begin the process of collating information on relevant plans and programmes and is Finaled in accordance to regulation R 982 dated 4 December 2014.
“shaft” A vertical or inclined excavation in rock for the purpose of providing access to an orebody. Usually equipped with a hoist at the top, which lowers and raises a conveyance for handling workers and materials.
“smelter” A metallurgical complex in which material is melted in order to separate impurities from pure metal.
“stockpile” Broken ore heaped on surface, pending treatment or shipment.
“stratigraphy” Strictly, the description of bedded rock sequences; used loosely, the sequence of bedded rocks in a particular area.
“tailings” Material rejected from a mill after most of the recoverable valuable minerals have been extracted.
“thickener” A large, round tank used in milling operations to separate solids from liquids; clear fluid overflows from the tank and rock particles sink to the bottom.
“waste” Includes any substance, material or object, that is unwanted, rejected, abandoned, discarded or disposed of, or that is intended or required to be discarded or disposed of, by the holder of that substance, material or object, whether or not such substance, material or object can be re-used, recycled or recovered.
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“waste classification” Means establishing: (i) whether a waste is hazardous based on the nature of its physical, health and environmental hazardous properties (hazard classes), and (ii) the degree or severity of hazard posed (hazard categories).
“wetland” A wetland is the land which is transitional between dry and wet systems, where the water table is usually at or near the surface, or the land is periodically covered with shallow water and which supports or would support vegetation that is adapted to life in saturated soil (National Water Act 36 of 1998 In DWAF, 2005).
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ABBREVIATIONS
BID Background Information Document BPG Best Practices Guideline CMA Catchment Management Agency
Cr2O3 Chromium (III) Oxide DEA Department of Environmental Affairs READ Department of Rural, Environment and Agricultural Development DMR Department of Mineral Resources (previously DME) DSR Draft Scoping Report DWS Department of Water and Sanitation EIA Environmental Impact Assessment EIAR Environmental Impact Assessment Report EPL Eastern Platinum Limited EMP Environmental Management Programme EMS Environmental Management System FSR Final Scoping Report GN General Notice GNR General Notice Regulation Ha Hectares HDSA Historically Disadvantage South Africans HR Human Resources I&APs Interested and Affected Parties IDP Integrated Development Plan IRR Issues and Responses Report IWULA Integrated Water Use Licence Application IWWMP Integrated Mine Water and Waste Management Plan LoM Life of Mine MAP Mean Annual Precipitation MAR Mean Annual Runoff mamsl Metres above mean sea level mbgl Metres below ground level MPRDA Mineral and Petroleum Resources Development Act 28 of 2002 Mm3 Million cubic metres m3 Cubic Metres m2 Square metres m Metres m/s Metres per second MSA Middle Stone Age Mt Million tones Mtpa Million tonnes per annum NEMA National Environmental Management Act 107 of 1998 NEMAQA National Environmental Management: Air Quality Act 39 of 2004 NEMPAA National Environmental Management Protected Areas Act NEMWA National Environmental Management: Waste Act 59 of 2008 NHRA National Heritage Resources Act 25 of 1999 NWA National Water Act 36 of 1998 NWRS National Water Resources Strategy
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PCD Pollution Control Dam PMR Precious Metal Refinery PPP Public Participation Process READ Department of Rural, Environment and Agricultural Development RoD Record of Decision SA South Africa SAHRA South African Heritage Resources Agency SANS South African National Standards SEF Safety Evaluation Flood SHE Safety, Health and Environment SWMP Storm Water Management Plan ToR Terms of Reference TWQGW Target Water Quality for Groundwater tph Tonnes per annum WMA Water Management Area WULA Water Use Licence Application
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1 INTRODUCTION AND BACKGROUND
Lonmin is the third largest producer of Platinum Group Metals (PGMs) and associated minerals in the world and has an employee number of about 24 000. The company is listed on the London Stock Exchange with a secondary listing on the Johannesburg Stock Exchange. The company owns the Marikana Operations as well as the Baobab operation situated in the Limpopo Province and the Precious Metal Refinery (PMR) located in Brakpan.
The Lonmin Platinum Operations in Marikana are divided into Western Platinum Limited (WPL) and Eastern Platinum Limited (EPL) with the Mining Rights area covering approximately 10,418 Ha (WPL) and 4,099 Ha (EPL). The Lonmin Platinum Mine Operations in Marikana stretches over approximately 35km situated immediately north of the N4 National route (also known as the Bakwena Highway). The entire mining area is situated between Marikana to the west and stretches another 4km past Bapong to the east.
The core business focus of Lonmin plc includes Platinum Group Metals (PGMs) such as platinum (Pt), palladium (Pd), rhodium (Rh), iridium (Ir), ruthenium (Ru), and gold (Au). Other refined by-products that are produced include copper, nickel sulphate and chromite. WPL and EPL are currently mining both the Merensky and Upper Group 2 Reef (UG2). The UG2 Reef is approximately 0.9 m – 1.1 m thick and runs parallel to and lies underneath the Merensky Reef (approximately 130 m to 210 m below). Together these two Reefs contain most of the world's known reserves of platinum group metals (PGMs) or platinum group elements (PGMs) Platinum, Palladium, Rhodium, Ruthenium, Iridium, Osmium and Gold.
Lonmin has a New Order Mining Licence for their core operations valid until 2037 and is renewable to 2067. Eastern Platinum Limited (EPL) is a subsidiary of Lonmin Platinum and has an approved Environmental Management Plan (EMP) dated 2012.
It is the intention of EPL to conduct an Environmental Impact Assessment in terms of the National Environmental Management Act (Act No. 107 of 1998) EIA Regulations as amended, and a Water Use License Application in terms of the National Water Act, 1998 (Act 36 of 1998) to allow for the construction and operation of the extension to the EPL Chrome Plant. The 2012 EMP will be updated as to include the construction of the proposed extension of the EPL Chrome Plant for life of mine operations.
1.1 Company Details
The contact details of the relevant parties have been listed in Table 1.1 below:
Table 1.1: Contact Details
Name of Applicant Postal Address Contact Person c/o Lonmin Platinum Gerald Daniels Private Bag X508 Senior Manager Concentrators Eastern Platinum Limited Marikana Tel: 014 571 5320 0284 Cell: 082 891 6744
Eastern platinum Limited is in possession of the following Mining Rights and Authorisations:
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Table 1.2: Lonmin – Mining Authorisations
Licence Holder License Number Approval Date and Expiration
Mining Right Commenced: 4 September 2007 Eastern Platinum Limited 109MR Mining Right End: 3 September 2037
Figure 1:1 Mining Rights Area (SEF, 2012)
1.2 Independence of the Environmental Assessment Practitioner
Alta van Dyk Environmental Consultants cc has been appointed as the independent Environmental Project Managers to conduct the environmental impact assessment for the proposed project supported by various independent specialists.
Alta van Dyk holds a Master’s Degree in Environmental Management from the University of North-West. In terms of professional affiliation, Alta van Dyk is registered with the South African Council for Natural Scientific Professions in Ecological Science, as well as Environmental Science fields of practice.
Alta van Dyk has been involved as the project manager in various EIAs in terms of the National Environmental Management Act (NEMA) (No 107 of 1998), the National Environmental Management Waste Act (NEMWA) (No 59 of 2008), the National Water Act (NWA) (No 36 of 1998) as well as the Minerals and Petroleum Resources Development Act (MPRDA) (No 28 of 2002). Her responsibilities included the overall management of the project, the identification and assessment of environmental impacts and the development of environmental management plans.
Alta van Dyk meets the requirements for independence as she does not have and will not have any financial interest in the undertaking of the activity, other than remuneration for
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work performed in terms of the EIA Regulations, 2014, and has no vested interest in the proposed activity proceeding, and also has no, and will not engage in, conflicting interests in the undertaking of the activity.
Table 1.3: Contact Details - Environmental Practitioner
Contact Person Company Details Postal Address Physical Address Alta van Dyk Environmental Alta van Dyk Postnet Suite #745 Consultants cc Stand 3698 Private Bag X 1007 2011/059764/23 4 Garcia Peak Email: Lyttelton Midlands Estate [email protected] 0140 Tel: +27 12 940 9457 Fax: 086 634 3967
A multi-disciplinary specialist team have been appointed to conduct different studies to determine the possible impacts the extension of the EPL Chrome Plant might have on the environment and which possible mitigation measures can be implemented to reduce the possible risks. The table below list the studies to determine the possible impacts for the extension of the EPL Chrome Plant on the environment:
Table 1.4: Specialist Team
Specialist Field Company Name Freshwater Ecological Stephen van Staden Scientific Aquatic Services Assessment Christel Pretorius Stephen van Staden Soil and Land Capability Scientific Aquatic Services Sinethemba Mchunu Emile van der Westhuizen Terrestrial Ecology Scientific Terrestrial Services Hennie de Beer Stephen van Staden Visual Impact Assessment Scientific Terrestrial Services Michelle Pretorius Hydrology E-TEK Consulting Paul Harris Hydrogeology Delta H Kai Witthueser Dr Julius CC Pistorius Heritage Archaeologist and Heritage Julius Pretorius Consultant
1.3 Properties
The Lonmin Platinum Marikana Operation stretches over an area of approximately 35km situated immediately north of the N4 National route (also known as the Bakwena Highway). The entire mining area is situated between Marikana to the west and stretches another 4km past Bapong to the east. Magaliesburg lies approximately 10km south east of the operation with Pretoria a further 46km to the east and Rustenburg a further 35km to the west.
The EMP amendment process is applicable to the EPL Mining Rights Area (MRA) only and is located within the boundaries of the Madibeng Local Municipality which forms part of the Bojanala Platinum District Municipality (BPDM). Although EPL has a number of Mining Rights over the eastern part of the Marikana operations, the following farm portion is relevant to the project is situated on the following farms (Refer to Figure 2.1 for a locality map).
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Boschfontein 458-JQ; Modderspruit 461-JQ; Turffontein 462-JQ; Kareepoort 407-JQ; Kafferskraal 460-JQ; and Middelkraal 466-JQ (portions 2 & 52).
Table 1.5: Property Information
Locality of proposed Property Description Owner on Title deed Title Deed Number new Chrome Plant Boschfontein 458JQ National Government of the T2035/1906BP N/A Portion 5 Republic of South Africa Modderspruit 461JQ National Government of the T147/1926BP N/A Portion 2 Republic of South Africa Kareepoort 407JQ Republic of T917/1883BP N/A Portion 1 Bophuthatswana National Government of the Kafferskraal 460JQ RE1 T970/1878BP N/A Republic of South Africa Middelkraal 466 JQ Western Platinum Limited T106571/1998 N/A Portion 52 The proposed new Chrome Plant will be Turffontein 462 JQ Republic of South Africa T147/1926BP located on the farm Turffontein 462 JQ
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2 DETAILED PROJECT DESCRIPTION
Lonmin is a primary producer of Platinum Group Metals (PGMs). These metals are essential for many industrial applications, especially catalytic converters for internal combustion engine emissions, as well as their widespread use in jewellery and investment. Saleable by- products produced from PGM mining include copper, nickel and chrome.
PGM mining involves the exploration, mining, concentrating, smelting, base metals extraction and refining from the ore mined at the opencast pits and the shafts. Exploration, mining and concentrating takes place at both Eastern Platinum Limited and Western Platinum Limited. The smelter and Base Metals Refinery are located within the Western Platinum Limited operations at Marikana. The final PGM concentrate from the Smelter/BMR is air freighted to the Precious Metals Refinery in Brakpan in the Gauteng Province.
The EIA and EMP Amendment will focus only on the operation at Eastern Platinum Limited. Western Platinum Limited is in possession of a separate Environmental Management Programme.
2.1 Existing Operations
The existing EPL operations include the following infrastructure:
Offices, Stores, bus depot; Mining Areas: o Underground Mining Areas (Shaft Areas); . Saffy Shaft; . E1 Incline Shaft; . E2 Incline Shaft; . E3 Incline Shaft o Opencast Operations; . Merensky Outcrop: M10b; M11; M12; . UG2 Outcrop: U12; U13; U14; U15. Processing; o EPC Concentrator; o EPL Concentrator; o Existing Chrome plant
Mine Residue Disposal Areas; o Tailings Storage Facilities . TD 1 and 2; . TD1 Easterns Bulk Tailings Treatment Plant o Waste Rock Dumps located at each shaft area; EPL Waste Water Treatment Works; General Waste Disposal Sites; o EPL General Waste Disposal Site (mothballed); Infill Apartments Various extensive pipeline and road networks
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2.2 Proposed New Infrastructure
The proposed EPL Chrome Plant extension will receive tails from Lonmin Concentrators via pipelines. Chromium (III) Oxide (Cr2O3) will be beneficiated by various gravity separation techniques. Cr2O3 concentrate will be partially dewatered via cyclones and deposited on a concrete slab, where once it has dried it will be loaded on side tipper trucks and removed from site. The tailings of the proposed plant will be returned to Lonmin Tailings Treatment Plant (TTP) for additional PGM recovery.
The development of the chrome plant will include the following: Site Offices; Chrome Processing Plant consisting of: o a chrome ore spiral plant; o thickeners; o product storage areas; Related infrastructure such as: o Storm Water Management facilities (Storm Water Dam and associated clean and dirty water separation infrastructure such as trenches, berms etc.); o Laydown area to be later used as a parking area; o Truck staging area (maximum 15 trucks); Security o Security and perimeter fence.
Services to the proposed Chrome Plant:
Water Supply o Potable water is supplied by the Rand Water Board (RWB). The Chrome Plant makes use of a closed water system entailing that water is constantly re-used and not disposed of. Water from the thickeners are removed and temporarily stored in the process water tanks before re-used in the process. Lonmin supplies the plant with process water from their concentrator plant. Power Supply o Eskom power is supplied via overhead lines to the area. The existing connection at the mine will be used with no additional power supply required Access Road o The existing Lonmin road network will be used for access to the Chrome Plant. No new roads would be required. Sewage Disposal o Sewage effluent will be connected to the exiting effluent pipelines and treated at the Licensed Eastern Platinum Limited Waste Water Treatment Works.
2.3 Life of Project
The Chrome Plant is a life-of-mine project.
2.4 Locality
EPL is situated approximately 46km from Pretoria and 45km from Rustenburg within the Bojanala Platinum District Municipality, in the North West Province. It is located within the Madibeng Local Municipal area. Figure 2.1 below illustrates the locality of the proposed Chrome Plant within the Lonmin EPL Operations (regional setting).
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Table 2.1: Outside Co-ordinates
Project Coordinates S2541’29.70” S2541’25.14” E2737’16.49” E2737’30.01” New EPL Chrome Plant S2541’29.63” S2541’25.33” E2737’30.24” E2737’16.82”
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Figure 2.1: Regional Setting of the Lonmin Operations (Highlands Hydrology, 2012)
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Figure 2:2 Locality Map of the EPL Chrome Plant
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Figure 2:3 Master Layout Plan (E-Tek, 2018)
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3 ALTERNATIVES CONSIDERED
The identification of alternatives is an integral part of the EIA/EMP process and is required in terms of the NEMA and NEMWA. This includes the “No-Go” option.
Table 3.1: Alternatives as provided through NEMA
Alternative Definition of Alternative These are sometimes referred to as project alternatives, although the term activity can be used in a broad sense to embrace policies, plans and programmes as well as Activity projects. Consideration of such alternatives requires a change in the nature of the proposed activity. Could be considered for the entire proposal or for a component of a proposal, for example the location of a processing plant. The latter is sometimes considered under Location site layout alternatives. A distinction should also be drawn between alternative locations that are geographically quite separate and alternative locations that are in close proximity. Various terms are used for this category, including technological alternative and Process equipment alternative. The purpose of considering such alternatives is to include the option of achieving the same goal by using a different method or process. Arise when a demand for a certain product or service can be met by some alternative Demand means. These are sometimes known as sequencing or phasing alternatives. In this case an Scheduling activity may comprise a number of components, which can be scheduled in a different order or at different times and as such produce different impacts. By their nature, input alternatives are most applicable to industrial applications that Input may use different raw materials or energy sources in their processes. Consideration of alternative routes generally applies to linear developments such as Routing power lines, transport and pipeline routes. Site layout alternatives permit consideration of different spatial configurations of an Site Layout activity on a particular site. In some cases, activities that can be broken down into smaller units can be undertaken Scale on different scales. Consideration of different designs for aesthetic purposes or different construction Design materials in an attempt to optimise local benefits and sustainability would constitute design alternatives.
The following alternatives were considered during the planning phase for the Eastern Platinum Limited new Chrome Plant.
Table 3.2: Alternatives for the proposed new Chrome Plant
Alternative Definition of Alternative considered An extension of the existing EPL chrome plant is required at the Eastern Platinum Activity Limited operations.
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Alternative Definition of Alternative considered • The preferred location for the construction of the new Chrome Plant is within the existing footprint area of the decommissioned surge dams next to the EPL Concentrator. In terms of the alternatives considered, the following aspects were taken into consideration:. o The proximity to the existing EPL Concentrator. This will reduce transportation cost. Location o Within the existing disturbed area, reducing the possible environmental impacts. o Usage of the existing access roads. o Have access to electricity. o Have access to the onsite WWTW o Within the mining rights area. o Have an existing surface right lease agreement. The chrome plant uses a standardised process to extract chrome, which has been Process optimised. There is no alternative for the existing proven technology and process. South Africa is the primary global chromium supplier. Chromium is used to harden steel, to manufacture stainless steel, to produce several alloys, chromium-plated car parts, chromium plate plastics and leather tanning. Chromium compounds are used as industrial catalysts and pigments (in bright green, yellow, red and orange colours). Chrome along with other metals are found along with platinum in the UG2 and Demand Merensky Reefs mined for platinum. Abstracting the chrome is a different process than abstracting platinum and requires a separate plant. As EPL continues to mine platinum and PGMs, there is a need and opportunity to process the chrome. Currently the existing chrome plants are situated at some of the other concentrators. Tailings currently need to be transported by truck to the chrome plants from the EPL Concentrator. Constructing the extension of the EPL Chrome Plant within the proximity of the concentrator will reduce the transportation costs. The project timing and implementation is driven by the need to increase the processing of chrome ore at the operations. This is however subject to financial and social Scheduling implications. The project timeframes has allowed for the environmental processes to be undertaken obtaining all relevant authorisations before construction will start. Using the existing electricity and water infrastructure is more cost effective and Input environmentally efficient. Existing proven technology is used. Routing The current access roads and powerlines will be used. No alternatives required. The site layout has been influenced by the locality of current infrastructure and Site Layout disturbed areas on site, property ownership and proximity to existing operations. The available processing capacity at the existing chrome plants along with production volumes has largely determined the scale of the proposed extension of the EPL chrome Scale plant. . The chrome plant is a small scale component of the mining process. The scale of the plant is directly related to production. To alternatively redesign the chrome plant layout and operations would be costly and unnecessary. The designs of the chrome plants have already been optimised over Design several years to improve the process, reduce waste generated and reduce water usage. There is no need for any alternative design as the most optimized chrome plant design has been standardised across the operations. By not constructing the extension of the EPL chrome plant, the mine will not be able to No-Go increase the chrome production at the operations. This could reduce the socio- Alternative economic impacts with no new job opportunities for the communities.
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4 LEGISLATIVE BACKGROUND
4.1 The Constitution of the Republic of South Africa (Act 108 of 1996)
The Constitution of South Africa compels all to ensure the rights of South African citizens. Section 24 of the constitution provides: Everyone has the right:
to an environment that is not harmful to their health or well-being; to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that: o prevent pollution and ecological degradation; o promote conservation; and o secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.
4.2 National Environmental Management Act, 1998 (Act no. 107 of 1998) and National Environmental Management Amendment Act, 2008 (Act No. 62 of 2008) (NEMA)
The National Environmental Management Act (NEMA) gives effect to the rights contained under section 24 of the constitution which states that “everyone has the right to an environment that is not harmful to their health or well-being; and to have the environment protected, for the benefit of present and future generations”. The NEMA provides for co- operative environmental governance by establishing principles for decision-making on matters affecting the environment. These principles include that development must be socially, environmentally and economically sustainable. NEMA sets out:
The fundamental principles that need to be incorporated in the environmental decision making process. The principles that is necessary to achieve sustainable development. Provides for duty of care to prevent, control and rehabilitate the effect of significant pollution and environmental degradation. It allows for the prosecution of environmental crimes.
In terms of the section 24(5) read with section 44 of the Act, Environmental Impact Assessment Regulations have been published that provides a list of activities that may require either a Basic Assessment (BA) or a full Scoping and Environmental Impact Assessment (EIA) process to be followed.
Government Notice No. 983 in Gazette No. 38282 on 4 December 2014, as amended on 7 April 2017 in Gazette No. 40772 as Government Notice No. 327 - Listing Notice 1; Government Notice No. 984 in Gazette No. 38282 on 4 December 2014, as amended on 7 April 2017 in Gazette No. 40772 as Government Notice No. 325 – Listing Notice 2; and Government Notice No. 985 in Gazette No. 38282 on 4 December 2014, as amended on 7 April 2017 in Gazette No. 40772 as Government Notice No. 324 – Listing Notice 3;
Table 4.1: List of Activities applied for
Regulation Listed Activity Activity description GNR 983 (Listing Activity 12 - The development of Development of a Chrome Notice 1) as Plant inclusive of the following
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amended on 7 (ii) infrastructure or structures with a physical footprint infrastructure: April 2017 in of 100 square metres or more • Site Offices Gazette No Where such development occurs – • Chrome Processing Plant 40772 as (a) Within a watercourse • Product Stockpile Areas Government (c) If no development setback exists, within 32 metres of • Process Water Tanks Notice No 327 a watercourse, measured from the edge of the • Thickeners (X3) Listing Notice 1. watercourse • Fire Suppression Tanks (X2) • Storm water management infrastructure and containment facilities • Laydown area and heavy vehicle parking area Infilling and terracing within close proximity of a delineated wetland system. Activity 19 – The infilling or depositing of any material of more than 10 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 cubic metres from a watercourse; but excluding where such infilling, depositing, dredging, Infilling and terracing within excavation, removal or moving— 500m of a delineated wetland a) will occur behind a development setback; system and bordering the 100m b) is for maintenance purposes undertaken in horizontal distance from the accordance with a maintenance management plan; drainage line for the c) falls within the ambit of activity 21 in this Notice, in construction of the Chrome which case that activity applies; Plant and associated d) occurs within existing ports or harbours that will not infrastructure. increase the development footprint of the port or harbour; or e) where such development is related to the development of a port or harbour, in which case activity 26 in Listing Notice 2 of 2014 applies Activity 21 - Any activity including the operation of that activity which requires a mining permit in terms of section 27 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), including — a) associated infrastructure, structures and earthworks, directly related to the extraction of a mineral resource; or Primary processing of chrome b) the primary processing of a mineral resource at the Chrome Plant including winning, extraction, classifying, concentrating, crushing, screening or washing; but excluding the secondary processing of a mineral resource, including the smelting, beneficiation, reduction, refining, calcining or gasification of the mineral resource in which case activity 6 in Listing Notice 2 applies Activity 6 –The development of facilities or infrastructure for any process or activity which requires a permit or GNR 984 (Listing licence or an amended permit or licence in terms of The project will require a Water Notice 2) as national or provincial legislation governing the Use Licence in accordance with amended on 7 generation or release of emissions, pollution or effluent, Section 21 of the National April 2017 in excluding─ Water Act from the Gazette N0 I. activities which are identified and included in Department of Water and 40772 as Listing Notice 1 of 2014; Sanitation for the construction Government II. activities which are included in the list of waste of stormwater management Notice No 325 management activities published in terms of and containment facilities. Listing Notice 2. section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National
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Environmental Management: Waste Act, 2008 applies; III. the development of facilities or infrastructure for the treatment of effluent, polluted , wastewater or sewage where such facilities have a daily throughput capacity of 2 000 cubic metres or less; or iv where the development is directly related to aquaculture facilities or infrastructure where the wastewater discharge capacity will not exceed 50 cubic metres per day.. Possible encroachment of site clearance at the vehicle parking GNR 985 (Listing area which may involve the loss Notice 3) as of natural habitat in a listed amended on 7 Activity 12 – The clearance of an area of 300 square critically endangered or April 2017 in metres or more of indigenous vegetation except where endangered ecosystem in Gazette No such clearance of indigenous vegetation is required for terms of Section 52 of the 40772 as maintenance purposes undertaken in accordance with a National Environmental Government maintenance plan. Management: Biodiversity Act, Notice No 324 2004 9Act No. 10 of 2004) - Listing Notice 3. Marikana Thornveld (SVcb6). Listed as Vulnerable.
4.3 Minerals and Petroleum Resources Development Act, 2002 (Act 28 of 2002)
The fundamental principles of the Act are:
Mineral resources are non-renewable; Mineral resources belong to the nation and the State is the custodian; Protection of the environment for present and future generations to ensure sustainable development of the resources by promoting economic and social development; The need to promote local and rural development of communities affected by mining; Reformation of the industry to bring about equitable access to the resources and eradicating discriminatory practices; and Guaranteeing security of tenure.
In terms of Section 102 (as amended 21 April 2009) of the MPRDA a mine may not amend a Mining Right, a Mining Works Programme, environmental management programme or an environmental authorisation issued in terms of the National Environmental Management Act, 1998, without the written consent of the Minister.
The purpose of this report is to support an application for the consent of the Minister in terms of Section 102 of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) (MPRDA) to amend the existing EMPR to include the proposed chrome plant extension.
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4.4 The National Environmental Management: Waste Act (Act 59 of 2008) (NEM:WA)
According to the NEM:WA, the purpose of this piece of legislation is:
“To regulating waste management in order to protect health and the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development; to provide for institutional arrangements and planning matters; to provide for national norms and standards for regulating the management of waste by all spheres of government; to provide for specific waste management measures; to provide for the licensing and control of waste management activities; to provide for the remediation of contaminated land; to provide for the national waste information system; to provide for compliance and enforcement; and to provide for matters connected therewith.”
No waste listings apply to this project. Overall waste management as is required by the NEMWA will apply to the project.
TO NOTE: The proposed new chrome plant will not require a waste management licence as only chrome ore will be stockpiles as run-of-mine reserves.
The classification of waste was however used in order to determine the liner requirements for the management of contaminated stormwater on site and the construction of a pollution control dam., and hence the reference to the regulations below.
Regulation R. 634 dated 23 August 2013 with regards to Waste Classification and Management Regulations; Regulation R 635 dated 23 August 2013 with regards to the National Norms and Standards for the assessment of waste for landfill disposal; and Regulation R 636 dated 23 August 2013 with regards to the National Norms and Standards for disposal of waste to landfill – Required Barrier Designs.
4.4.1 Waste Classification and barrier requirements
The DWS has adopted the National Environmental Management: Waste Act, 2008 (Act no. 59 of 2008) National Norms and Standards for the assessment of waste for Landfill Disposal dated 23 August 2013 as the methodology for the classification of waste, where based on the Total Concentration (TC) and Leachable Concentration (LC) limits of the elements and chemical substances in the waste exceeding the corresponding TCT and LCT limits respectively, the specific type of the waste is determined.
TCLP Leach (Acidic leach – pH of 5) – Typical condition of a general landfill site where putrescible/biodegradable waste is disposed of. Borax Leach (Alkaline leach – pH of 9.3) – Typical of a site where alkaline wastes and no putrescible wastes are disposed of. Distilled Waste Leach (neutral leach reagent water – pH of 7) – Typical of a mono- disposal site, where no putrescible wastes are disposed of. Rain water would be the only liquid coming into contact with this waste. As this is the condition that would prevail on site, the distilled leach values will be deemed as the most representative for the determination of barrier requirements on site.
The specific type of waste is determined by the total concentration in the water.
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Important definitions to consider are:
The Total Concentration is defined as the total concentration of a particular element or chemical substance in a waste expressed as mg/kg. The Leachable Concentration is defined as the leachable concentration of a particular element or chemical substance in a waste expressed as mg/l . Leaching means - to remove (a chemical, a metal, etc.) from a substance by the action of a liquid passing through the substance: to release (a chemical, a metal, etc.) when a liquid passes through. Published GN R. 636 of 2013 stipulates the following disposal barrier requirements associated with the different waste types:
Table 4.2: Landfill Disposal Requirements
Waste Type Landfill Disposal Requirements The disposal of Type 0 waste to landfill is not allowed. The waste must be treated Type 0 Waste and re-assessed in terms of the Standard for Assessment of Waste for Landfill Disposal. Type 1 waste may only be disposed of at a Class A landfill designed in accordance with Section 3(1) and 3(2), or, subject to Section 3(4), may be disposed of at a Type 1 Waste landfill site designed and operated in accordance with the requirements for a Hh / HH landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998). Type 2 waste may only be disposed of at a Class B landfill designed in accordance with Section 3(1) and 3(2), or, subject to Section 3(4), may be disposed of at a Type 2 Waste landfill site designed and operated in accordance with the requirements for a GLB+ landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998). Type 3 waste may only be disposed of at a Class C landfill designed in accordance with Section 3(1) and 3(2), or, subject to Section 3(4), may be disposed of at a Type 3 Waste landfill site designed and operated in accordance with the requirements for a GLB+ landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998). Disposal allowed at a landfill with a Class D landfill designed in accordance with Section 3(1) and 3(2), or, subject to Section 3(4), may be disposed of at a landfill Type 4 Waste site designed and operated in accordance with the requirements for a GLB- landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).
4.5 National Environmental Management Air Quality Act, 2008 (Act 39 of 2008)
4.5.1 Dust Fall-out
The National Dust Control Regulations (Government Gazette 1 November 2013, Regulation R 827 dated 1 November 2013) recommends that no person may conduct any activity in such a way as to give rise to dust in such quantities and concentrations that: i) The dust, or dust fall, has a detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage, or has contributed to the degradation of ambient air quality beyond the premises where it originates; or a. The dust remains visible in the ambient air beyond the premises where it originates; or
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b. The dust fall at the boundary and beyond the boundary of the premises where it originates exceeds: ii) 600 mg/m2/day averaged over 30 days in residential or light commercial areas measured using reference method ASTM D1739; or iii) 1 200 mg/m2/day averaged over 30 days in areas other than residential and light commercial areas measured using reference method ASTM D1739.
Table 4.3: Acceptable Dust Fall Rates
Dust Rate (D) Permitted frequency of exceeding dust Restricted Areas (mg/m2/day, 30-days average) fall rate Residential Area D < 600 Two within a year, not sequential months Non-residential Area 600 < D < 1200 Two within a year, not sequential months
The method to be used for measuring dustfall rate and the guideline for locating sampling points shall be ASTM D1739: 1970, or equivalent method approved by any internationally recognized body.
According to the regulations, any person conducting any activity in such a way as to give rise to dust in quantities and concentrations that exceeded the dust fall standard set out in the regulation was impelled to, upon receipt of a notice from an air quality officer; implement a dust fall monitoring programme.
Enforcement of the regulation could have implications for the extension of the EPL Chrome Plant. This may include the development and implementation of a fugitive dust control plan and ambient dust monitoring.
4.5.2 Regional Air Quality Management Plan
The proposed extension of the EPL Chrome Plant is located in the Madibeng Local Municipality in the North West province. It is therefore a key stakeholder in the Air Quality Management Plan (AQMP) for the North West Province. The AQMP has six goals, the achievement of which aims to improve air quality management in the Province, and in turn, improve air quality. The six overarching goals are: i) To develop and maintain institutional arrangements that support sound air quality management and governance in the Province; ii) To reduce the negative impact on human health and environment of poor air quality; iii) To reduce impacts of fossil fuels in residential applications; iv) To address the effects of emissions from industrial sources; v) To quantify and reduce transport air emissions within the Province; and vi) To ensure effective communication and public participation in pursuant to legal requirements.
The Minister of Water and Environmental Affairs declared the Waterberg-Bojanala Priority Area (WBPA) on 15 July 2012 by the publication of Government Notice 495 in the Government Gazette (DEA, 2012b). A national Priority Area is a defined geographical area that extends beyond provincial boundaries within which ambient air quality standards are being, or may be exceeded, causing health and environmental impacts. The declaration implies that the declared area requires specific air quality management action to rectify the situation. The WBPA includes the Waterberg District Municipality in the Limpopo Province and the Bojanala-Platinum District Municipality and North West Provinces.
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In terms of Section 19 of the AQA, the national AQO must prepare a priority area air quality management plan (AQMP) for the area for submission to the Minister for approval. Lonmin Plc and Glencore are key stakeholders in the development of the WBPA AQMP.
4.6 National Water Act, 1998 (Act 36 of 1998)
The purpose of the National Water Act (Act 36 of 1998) (NWA) is to ensure that the nation’s water resources are protected, used, developed, conserved, managed and controlled. Use of water for mining and related activities is also regulated through regulations that were updated after the promulgation of the NWA (Government Notice No. GN704 dated 4 June 1999). Sections 40 and 42 of NWA provides for the responsible authority to request public participation and an assessment of the likely effect of the proposed license the protection, use, development, conservation, management and control of the water resource.
The following chapters of the NWA are of particular importance: Chapter 3, Part 4 states that anyone who owns, occupies, controls or uses land is deemed responsible for taking measures to prevent pollution of water resources; Chapter 4 deals with water use regulation; Chapter 12 deals with water management in terms of dam safety; Section 19 deals with water management at mines in terms of pollution prevention and control; Section 21 defines the water uses requiring authorisation; Section 26 (1) provides for the development of regulations requiring monitoring, measurement and recording as well as the effects to be achieved through management practices prior to discharge or disposal.
Section 21 of the NWA defines 11 consumptive and non-consumptive water uses: 21(a): Taking water from a water resource. 21(b): Storing water 21(c): Impeding or diverting the flow of water in a watercourse. 21(d): Engaging in a stream flow reduction activity. 21(e): Engaging in a controlled activity. 21(f): Discharging waste or water containing waste into a water resource through a pipe, canal, sewer or other conduit. 21(g): Disposing of waste in a manner which may detrimentally impact on a water resource. 21(h): Disposing in any manner of water which contains waste from, or which has been heated in any industrial or power generation process. 21(i): Altering the bed, banks, course or characteristics of a watercourse. 21(j): Removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people. 21(k): Using water for recreational purposes.
Water uses that are not permissible in terms of Schedule 1 of the NWA need to be authorised under a tiered authorisation system as a General Authorisation in terms of the General Authorisations as published under section 39 of the NWA or as a water use licence, as provided for in terms of section 21 of the NWA.
An existing lawful water use (ELWU) is a water use that lawfully took place in the period of two years before the commencement of the National Water Act (Act 36 of 1998). This allows any water use that lawfully took place to continue until such time as it can be converted into a license.
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The authorisation system allows for the “Reserve” and provides for public consultation processes in the establishment of strategies and decision making and guarantees the right to appeal against such decision.
Section 27 of the NWA specifies that the following factors regarding water use authorisation be taken into consideration:
The efficient and beneficial use of water in the public interest. The socio-economic impact of the decision whether or not to issue a licence. Alignment with the catchment management strategy. The impact of the water use and possible resource directed measures; and. Investments made by the applicant in respect of the water use in question.
The NWA introduced the concept of Integrated Water Resource Management (IWRM), comprising all aspects of the water resource, including water quality, water quantity and the aquatic ecosystem quality. The IWRM approach provides for both resource directed and source directed measures. Resource directed measures aim to protect and manage the receiving environment, whilst source directed measures aim to control the impacts at source.
The following water uses will require authorisation in terms of the National Water Act for the proposed development:
Table 4.4: List of applicable Water Uses requiring approval
Section 21 Water Use Activity which require the Water Use Licence Storage of clean water on site i.e. Fire (b) - Storage of water. Suppression Tanks (c) – impeding or diverting the flow of water Constructing infrastructure within 100m of a in a watercourse drainage line (i) – altering the bed, banks, course or Constructing infrastructure within 500m of a characteristics of a watercourse delineated wetland area. Product storage areas i.e. Ore Stockpiles (g) - Disposing of waste in a manner which Clean and dirty water separation and may detrimentally impact on a water containment facilities i.e. Pollution Control resource Facility
4.6.1 GN704 Requirements
The Minister of Water Affairs is responsible for the protection, use, development, conservation, management and control of the water resources of South Africa on a sustainable basis. The requirements prescribed in terms of the regulations must be seen as minimum requirements to fulfil this goal.
Table 4.5: GN704 requirements
Regulation
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Regulation No person in control of a mine or activity may- a) locate or place any residue deposit, dam, reservoir, together with any associated structure or any other facility within the 1:100 year flood-line or within a horizontal distance of 100 metres from any watercourse or estuary, borehole or well, excluding boreholes or wells drilled specifically to monitor the pollution of groundwater, or on water-logged ground, or Restriction on ground likely to become water-logged, undermined, unstable or on Locality cracked; b) except in relation to a matter contemplated in regulation 10, carry on any underground or opencast mining, prospecting or any other operation or activity under or within the 1:50 year flood-line or within a horizontal distance of 100 metres from any watercourse or estuary, whichever is the greatest; Every person in control of a mine or activity must: a) confine any unpolluted water to a clean water system, away from any dirty area; b) design, construct, maintain and operate any clean water system at the mine or activity so that it is not likely to spill into any dirty water system more than once in 50 years; c) collect the water arising within any dirty area, including water seeping Capacity from mining operations, outcrops or any other activity, into a dirty water requiremen system; ts for clean d) design, construct, maintain and operate any dirty water system at the and dirty mine or activity so that it is not likely to spill into any clean water system water more than once in 50 years; and systems e) design, construct, maintain and operate any dam or tailings dam that forms part of a dirty water system to have a minimum freeboard of 0.8 metres above full supply level, unless otherwise specified in terms of Chapter 12 of the Act. f) design, construct and maintain all water systems in such a manner as to guarantee the serviceability of such conveyances for flows up to and including those arising as a result of the maximum flood with an average period of recurrence of once in 50 years.
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Regulation Every person in control of a mine or activity must take reasonable measures to: a) prevent water containing waste or any substance which causes or is likely to cause pollution of a water resource from entering any water resource, either by natural flow or by seepage, and must retain or collect such substance or water containing waste for use, re-use, evaporation or for purification and disposal in terms of the Act; b) design, modify, locate, construct and maintain all water systems, including residue deposits, in any area so as to prevent the pollution of any water resource through the operation or use thereof and to restrict the possibility of damage to the riparian or in-stream habitat through erosion or sedimentation, or the disturbance of vegetation, or the alteration of flow characteristics; c) cause effective measures to be taken to minimise the flow of any surface water or floodwater into mine workings, opencast workings, other workings or subterranean caverns, through cracked or fissured Protection formations, subsided ground, sinkholes, outcrop excavations, adits, of water entrances or any other openings; resource d) design, modify, construct, maintain and use any dam or any residue deposit or stockpile used for the disposal or storage of mineral tailings, slimes, ash or other hydraulic transported substances, so that the water or waste therein, or falling therein, will not result in the failure thereof or impair the stability thereof; e) prevent the erosion or leaching of materials from any residue deposit or stockpile from any area and contain material or substances so eroded or leached in such area by providing suitable barrier dams, evaporation dams or any other effective measures to prevent this material or substance from entering and polluting any water resources; f) ensure that water used in any process at a mine or activity is recycled as far as practicable, and any facility, sump, pumping installation, catchment dam or other impoundment used for recycling water, is of adequate design and capacity to prevent the spillage, seepage or release of water containing waste at any time; g) at all times keep any water system free from any matter or obstruction which may affect the efficiency thereof. Every person in control of a mine or activity must- a) cause any impoundment or dam containing any poisonous, toxic or injurious substance to be effectively fenced-off so as to restrict access thereto, and must erect warning notice boards at prominent locations so as to warn persons of the hazardous contents thereof; b) ensure access control in any area used for the stockpiling or disposal of any residue or substance which causes, has caused or is likely to cause pollution of a water resource so as to protect any measures taken in Security and terms of these regulations; additional c) not allow the area contemplated in paragraph (a) and (b) to be used for measures any other purpose, if such use causes or is likely to cause pollution of a water resource; and d) protect any existing pollution control measures or replace any existing pollution control measures deleteriously affected, damaged or destroyed by the removing or reclaiming of materials from any residue deposit or stockpile, and establish additional measures for the prevention of pollution of a water resource which might occur, is occurring or has occurred as a result of such operations.
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4.7 Other legislation
Other legislation that may require consideration during the process include the following:
Table 4.6: Other Legislation
Legislation Applicability The Act requires all developers (including mines), to undertake cultural heritage studies for any development exceeding 0.5 ha and linear developments greater than 300m. It also provides guidelines for impact assessment studies to be undertaken whenever cultural resources may be destroyed by development National Heritage activities. Resources Act, 1999 (Act Permits must be acquired from the South African No. 25 of 1999) Heritage Resources Agency (SAHRA) before a heritage site (including graves and cemeteries) can be affected or destroyed during development activities. Lonmin has a heritage inventory of their entire site. There are no heritage sites within the project area. Conservation of CARA sets out to combat invasive plants. The Act categorizes Agricultural Resources weeds into three categories, with varying degrees of action Act, 1983 (Act No. 43 of required for each category of weeds. 1983) NEMBA aims to provide for the management and conservation of South Africa’s biodiversity within the framework of the NEMA, through the following mechanisms: The protection of species and ecosystems that warrant national protection; The sustainable use of indigenous biological resources; National Environmental The fair and equitable sharing of benefits arising from bio- Management: prospecting involving indigenous biological resources; and Biodiversity Act, 2004 The establishment and functions of a South African National (Act No. 10 of 2004) Biodiversity Institute.
The Marikana Thornveld is listed as a vulnerable ecosystem. The extension of the EPL Chrome Plant project will require environmental approval under Listing Notice 3 of the National Environmental Management Act, 1998 (Act 107 of 1998)
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5 ENVIRONMENTAL STATUS QUO
5.1 Topography
The North West Province is typically flat or has gently undulating plains within its central and western regions, whist the eastern region varies in typography which also produces the Magaliesburg mountain range. The altitude of the North West Province ranges from 920 - 1782 m above sea level. The typography of EPL is typically very flat to slightly undulating and lies within a seemingly eastwest valley bottom.
The mine area is situated between two hills (Magaliesburg and Kareepoortberg) which have an average of 100-180m above the surrounding plains with the highest points being 1357m above sea level. The catchment area is drained by the Crocodile River and associated tributaries in a northern direction.
5.2 Climate
Climatic conditions in the North West Province vary significantly from west to east. The far western region is arid (receiving less than 300mm of rainfall per annum), encompassing the eastern reaches of the Kalahari Desert. The central region of the Province is dominated by typically semiarid conditions, with the eastern region being predominantly temperate.
On average the eastern regions of the province receive over 600mm per annum with 70% of the annual rainfall occurring during the October to February period and the dominant rainfall occurring in December. Most of the rainfall in this region results from showers and thunderstorms with the average thunderstorm lasting between 30 and 60 minutes.
Long-term monthly average rainfall for the towns around the operations are illustrated in the graphs in Figure 5.1 and Figure 5.2.
Figure 5:1 Average monthly precipitation and rainfall days for Rustenburg (World Weather Online, 2017)
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Figure 5:2 Average monthly precipitation and rainfall days for Brits (World Weather Online, 2017)
5.2.1 Temperature
The North West Province is characterised by great seasonal and daily variations in temperature, being very hot in summer (daily average high temperatures of 32C in January) and mild too cold in winter (average daily minimum in July is 0.9C). The eastern regions of the Province have a seasonal fluctuation in temperature of between 12C and 15C.
The average annual temperature recorded at Lonmin Platinum is approximately 19C. Hot days with temperatures in excess of 30C (dry bulb) are commonly experienced in the region with between 5 and 28 very hot days occurring annually. Hot nights with temperatures higher than 16, 5C are a regular occurrence during the summer months.
Table 5.1: Temperatures (0C) for Lonmin Platinum (2002)
Temperature Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec (0C) Average 22.2 22.8 22.1 20.0 15.8 12.6 12.5 16.6 18.3 21.1 21.5 21.7 Maximum 31.8 35.0 32.3 30.3 28.0 24.3 28.3 27.2 31.7 35.9 34.4 32.1 Minimum 16.0 14.3 10.4 9.58 2.51 4 1.84 6.20 4.59 7.01 7.01 12.8
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Figure 5:3 Long-term monthly maximum and minimum temperatures (0C) for Rustenburg (World Weather Online, 2017)
Figure 5:4 Long-term monthly maximum and minimum temperatures (0C) for Brits (World Weather Online, 2017)
5.2.2 Evaporation
Evaporation is a function of ambient temperature, wind and the saturation deficit of the air. Relatively high levels of evaporation occur in the North West Province as a result of the elevated solar radiation levels experienced. The average evaporation for the region is
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between 1700mm and 1800mm per annum. The maximum evaporation rate occurs in December, with a mean rate of more than 7 mm per day.
For the majority of the Province the evaporation exceeds the precipitation resulting in a marked moisture deficit in the region. The long-term average monthly rainfall and evaporation rates recorded are presented in Table 5.2.
Table 5.2: Long-term monthly average evaporation
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Evaporation 162 143 130 132 99 64 70 95 129 155 158 163
5.3 Geology
The geology of the area comprises of the Rustenburg Layered Suite of the Bushveld Complex, which is thought to be the world's largest mafic-ultramafic layered intrusion which underlies an area of roughly 66,000 km2. The Bushveld complex which is well known for its large platinum and palladium resources consist of three different ore bodies namely:
Merensky Reef; Upper Group (U2) Chromotite; and Platreef.
EPL is situated within the western limb of the Bushveld Complex as illustrated in Figure 5.5. The Rustenburg Layered Suite is the collective name for the mafic-ultramafic rocks found in the Bushveld Complex and has been subdivided into zones namely the Marginal, Lower, Critical, Main and Upper Zones which ranges from the base of the Suite to the top of the Suite. Of significant importance is the Critical Zone which contains chromium and Platinum Group Minerals (PGM’s) within the Bushveld Complex.
The Critical Zone is host to both the Merensky Reef and UG2 Reef which are found in the upper subzone. The Merensky Reef lies above the UG2 Reef (approximately 130 m to 210 m above) with both economic layers exhibiting a general east to west strike trend. Dips vary from approximately 12 degrees in the south to around 10 degrees in the northern area. The Merensky reef and UG2 reef are therefore expected to be at depths of 1 250 m and 1 400 m respectively in the deepest parts of the mining area.
Underground mining operations at EPL consist of the UG2 Reef whilst the EPL-Opencast operations are focused on the Merensky and UG2 Reefs of the Upper Critical Zone.
5.3.1 Upper Critical Zone (UCZ)
The UZC contains alternating layers of pyroxenite, norite, spotted anorthosites, mottled anorthosites and chromitite. The prominent pyroxenite layers consist of Merenskry Pyroxenite and the UG2 Pyroxenite. These are commonly porphyritic with pematatitic zones occurring within the Merensky Pyroxenite. Norites often form thick layers and comprise equal amounts of cumulus plagioclase and bronzite. Spotted anorthosites consist of cumulas plagiolcoase and postcumulus bronzite while the mottled anorthosites consist of cumulus plagiocloase with intercumulus bronzite, forming oikocrysts.
5.3.2 Merensky Reef The Pyroxenite thickness within the Merensky Reef ranges between 0.3 m (KM area) and 12m (EPL area) with lateral variation in thickness and PGM mineralization across the strike length.
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Merensky Pegmatoid (course grained feldspatic pyroxonite) underlies the Merensky Pyroxenite in the western side of the lease area. According to the EPL EMPr (2005), Chromotite stringers (1-10mm) are present on the pyrxonenite/pegmatoid contact (Lower Chromotite Stringer) and the pegmatoid/footwall contact (Basal Chromitite Stringer).
With the increase in thickness of the Pyroxenite, an additional Chromitite stringer (1-2mm thick) known as the Upper Chromitite Stringer occurs from 20 cm to 100 cm below the upper contact. (Lower Chromotite Stringer) and the pegmatoid/footwall contact (Basal Chromitite Stringer). The Merensky Reef is classified into four major facies at the LPMO according to the combinations of the lithology, the thickness of the Merensky Pyroxenite and the PGM value distribution and is known as Westplats Reef type, Marikana Reef type, R.P.M Reef type and the Thin Reef type.
5.3.3 UG2 Chromite Layer
The UG2 Chromitite Layer lies beneath the Merensky Reef by between 130 m and 210 m, the middling between the two reefs gradually increasing across the lease area from west to east (Lonmin Mineral Resource and Mineral Reserve Statements, 2010). The thickness of the UG2 layer varies from 0.7 m to 1.3 m and the entire layer is removed during the mining operation. At EPL, a thin layer of feldspatic Pyroxenite is often present and is disrupted by sections of bifurcating stringers and layer of Chromitite and anorthosites with the number of anorthosites layers varying between 1 to over 100.
The UG2 consist of Chromitite (60-90% by volume), orthopyroxene (5-25% of volume), plagioclase (5- 15%) and accessory amount of other sulphides, platinum-group minerals, ilmenite and magnetite (McLaren & De Villiers, 1982).
Figure 5:5 Regional Geology: Bushveld Igneous Complex
5.4 Soils
The Witbank and black turf Arcadia soil forms dominate the landscape of the project area, with Rensburg soils associated with the wetlands in the south-eastern section of the project area. Mispah soils can be found in a very small area at the rocky outcrop. A large portion
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within the project area has been under significant human disturbance for a considerable number of years, attributable to mining activities.
5.4.1 Agricultural Potential
The agricultural potential of land within the South African context is of high value in terms of sustainability principles. The agricultural potential or also referred to as land capability is determined by physical environmental parameters such as climate conditions and soil characteristics. In respect of the EPL MRA, the following three classes of land capability are present:
Arable land - Crops commonly produced on the Arcadia soils include sunflower, maize, sorghum and vegetables. Commercial crop production, as opposed to subsistence farming, requires the use of mechanical implements to overcome mechanical constraints imposed by the high clay content of the soils. Currently the cash crops comprise of sunflowers (63%), soya beans (4%) and sorghum (33%). Due to the characteristics of the soil type, namely depth and structure, a reasonable return to a pre-mining land use can be accomplished in terms of arable land;
Grazing land – Based on a low rainfall figure within the North West Province (600 to 650mm/ annum), livestock farming, under normal circumstances, is inhibited by this relative low rainfall and the resulting low carrying capacity of the veld. The carrying capacity of available grazing land in the area is estimated to be one large stock unit per 8 to 12 ha; and
Wilderness land - Wilderness land has little or no agricultural capability, as it is not favourable for agriculture production due to the land being either too steep or too rocky. The various koppies found within the Lonmin Marikana area including the northern foothills of the Magaliesburg to the south and the Kareepoortberg situated to the north, results in these rocky areas being classifies as land with “Wilderness Land” capability.
5.4.2 Land Use
The mining right areas of the Lonmin Platinum Marikana Operation (Including both WPL and EPL) consist of:
Lonmin owned land; Tribal land (kept in trust by the State); Private owners and famers land; Servitudes for rail and electricity
The EPL operations are situated on tribal land.
The Bapo Ba Mogale Tribe are the registered owners of the farms:
Boschfontein 458-JQ; Modderspruit 461-JQ; Turffontein 462-JQ; Kareepoort 407-JQ; and Kafferskraal 460-JQ;
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Notorial Lease agreements are in place as necessary for the properties within the mine lease area owned by tribal authorities. Surrounding land uses include town/ settlements such as Bapong and Segwaelane, other mining operations (i.e. Glencore, Sibanye Stillwater and Tharisa Mine) including their associated infrastructure which relates to social services such as schools and medical facilities. Other land uses include formal towns (i.e. Mooinooi, Marikana etc), smallholdings, and farming activities.
5.5 Flora
The vegetation type at EPL is identified as Rustenburg Gabbro Thornveld (Low, A.B. & Rebelo, A.G., 1996). According to the CHEMC Fauna and Flora Report (2005) for the entire Lonmin Platinum Marikana Operation four main habitat types are applicable to the EPL area, namely:
Grassland Habitats: This habitat varies greatly in size and in ecological diversity and is not truly a natural habitat, but has been established through the rehabilitation of disturbed areas, agricultural activities, etc.; Turf Thornveld (Bushveld) Habitats: Main habitat type identified within EPL and consists of grassland intercepted with both thorn and other trees. Trees within the area typically identified as: Combretum molle, Croton gratissimus, Ficus soldanella, Pappea capensis, Bridelia mollis, Canthium huilense, Clerodendrum glabrum, Combretum apiculatum, Diplorhynchus condylocarpon, Dombeya rotundifolia, Euclea natalensis, Euphorbia cooperi, Ficus sonderi, Lannea discolor, Peltophorum africanum, Sclerocarya birrea, Shrubs: Grewia flavescens, Pouzolzia hypoleuca, Vitex zeyheri; Aquatic Habitats: The aquatic habitats identified include rivers, streams, wetlands, dams and the associated vegetation of these habitats. Perennial and non-perennial streams are found within EPL; and Granite Hills and Outcrops: Within the Turf Thornveld, granite outcrops of varying size are encountered. These outcrops and hills (at Segwealanie) form noticeably different habitats to the Turf Thornveld.
Significant disturbance exists within these habitats in the form of agricultural lands or settlements which have led to the removal of natural vegetation. Some of the areas are characterised by overgrazing where other areas of declared weeds and invader species. According to the (NWDACE, 2003), EPL is situated within an area containing medium hyperdiversity (meaning diversity within a taxon) that contains more species, general or higher ranked groups) and high hyperdiversity for the river systems areas.
In addition to the above-mentioned habitat types, large portions of the mine consist of agricultural lands or settlements. The agricultural lands have resulted in the complete removal of the natural vegetation. The vegetation surrounding the settlement areas is characterized by overgrazing and bush encroachment. A large number of declared weeds and invaders were also identified in these areas, as these plants were originally planted as “garden plants” in many of the areas.
Alien vegetation was recorded in 46% of the 190 surveyed plots (2008). The majority of declared alien vegetation was observed in formal settlements followed by old fields, drainage lines, riparian areas, natural woodlands and mine dumps and pits.
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5.5.1 Rare, Endangered and Protected Species
Two species listed under the Old Transvaal Ordnance of 1983 (No. 12 of 1983) were identified within the Lonmin Platinum Marikana Operation area namely, Eucmos autumnalis (south eastern section of the site) and Gladiolus spp. A permit is needed to remove, replant or transport these plants.
Furthermore three Protected Tree species might also present within the boundaries of Lonmin Platinum Marikana Operations according to Schedule No. 1042 dated 10 September 2004 (published in Government Gazette No. 26752) namely Combretum imberbe, Boscia albitrunca and Sclerocarya birrea. A permit is also necessary for the removal of these trees.
5.5.2 Alien Invasive Species
The invasive status of the listed species is classified into four categories, in accordance with the National Environmental Management Act: Biodiversity (Act 10 of 2004) and the Conservation of Agricultural Resource Act (43 of 1983):
Category 1a: invasive species that may not be owned, imported into South Africa, grown, moved, sold, given as a gift or dumped in a waterway. These species need to be controlled by the land-user, and officials from the Department of Environmental Affairs must be allowed access to monitor or assist with control. Category 1b: invasive species that may not be owned, imported into South Africa, grown, moved, sold, given as a gift or dumped in a waterway. Category 1b species are major invaders that may need government assistance to remove. All Category 1b species must be contained, and in many cases they already fall under a government sponsored management programme. Category 2: These are invasive species that may only remain on a property with the acquisition of a permit, which is granted under very few circumstances. These invader plants can only be grown in areas demarcated as a site where such plants and be established and retained. The demarcation of such areas may only be determined by the “Executive Officer”, appointed to administer the Conservation of Agricultural Resources Act. Any of these species found outside of such demarcated areas should be considered weeds and the land-owner/user is required to take control measures. Category 3: These are invasive species that can remain on your property. However, you cannot propagate or sell these species and must control them. In riparian zones or wetlands all Category 3 plants become Category 1b plants.
The National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) aims to provide for the management and conservation of South Africa’s biodiversity within the framework of the NEMA. The EPL chrome plant will apply for environmental authorisation is accordance with Listing Notice 3 of the National Environmental Management Act, 1998 (Act 107 of 1998) to construct the plant within the Marikana Thornveld.
A complete list of alien invasive species will be complied in the specialist study conducted during the Environmental Impact Assessment Report.
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5.6 Fauna
This section is largely based on the Fauna Survey undertaken by Ageenco Environmental Projects in 2015. According to this survey, the EPL MRA is found to have:
A high bird species diversity occurring due to the presence of aquatic habitats created by mine related activities and natural vegetation. A low number of game birds were noticed at EPL which could be the result of poaching by the local residents or the presence of stray dogs on site (presumable from adjacent township areas); and A low mammal and reptile diversity as a result of mining activities, settlements and grazing practices exercised by the surrounding community.
5.6.1 Rare and Endangered Species
One Red Data mammal species, Atelerix frontalis, the South African Hedgehog, a Near Threatened species occurs within the mine boundaries.
5.7 Air Quality
Ambient air quality is determined by the cumulative impact of a variety sources and the meteorological conditions prevalent. Meteorological conditions govern the dispersion, transformation and eventual removal of pollutant from the atmosphere. Ambient concentration levels therefore fluctuate in response to changes in atmospheric stability, variations in the mixing depth, and shifts in the wind field. Spatial variations and diurnal and seasonal changes in the wind field and stability regime are functions of atmospheric processes operating at various temporal and spatial scales.
Sources of air pollution for the North West Province and the Madibeng Local Municipality (MLM) influencing the Lonmin ambient environment are depicted in the Table 5.3 below.
Table 5.3: Sources of pollutants NW Province and Madibeng
Pollutant Associated Sources Domestic fuel burning, biomass burning, industrial operations, mining and associated activities, agricultural activities, vehicle Particulate Matter (PM) entrainment from unpaved roads, informal waste combustion, wind-blown dust from open areas, vehicle tailpipe emissions. Domestic fuel burning, biomass burning, industrial operations, mining and associated activities, agricultural activities, vehicle Sulphur Dioxide (SO2) entrainment from unpaved roads, informal waste combustion, wind-blown dust from open areas, vehicle tailpipe emissions. Fossil fuel combustion, vehicle tailpipe emissions, industrial Nitrogen Dioxide (NO2) processes, biomass burning. Vehicle tailpipe emissions, industrial operations, commercial Carbon Monoxide (CO) fuel burning appliances, domestic fuel burning, biomass burning. Vehicle tailpipe emissions, domestic fuel burning, biomass Ozone (O3) burning Unpaved roads, agricultural activities (seasonal), mining related Fallout Dust (TSP) activities
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Lead (Pb) Vehicle tailpipe emissions Vehicle tailpipe emissions, domestic fuel burning, filling Benzene (C6H6) stations, Domestic fuel burning, landfills, biomass burning, wastewater Methane (CH4) treatment (Sources taken from the North West Province Air Quality Management Plan and the Rustenburg Local Municipality Air Quality Management Plan)
Certain ambient parameters are employed and monitored to assess the ambient air quality at sensitive receptors sites located in an around EPL. The EPL Chrome Plant is expected to only generate nuisance dust.
5.8 Groundwater
The topography of an area determines the groundwater flow. The topography at EPL dips towards a northerly direction at a gradient of less than 5%. The area is underlain by a black silty clay (turf soil) layer varying from 1 m to 3 m in thickness. This layer is followed by an eroded norite-gabbro or weather and fractured anthrosite which is again followed by hard rock norite-gabbro. It is generally expected that the groundwater flow occurs mostly along the fractures of the underlying geology and entering into surface water bodies such as the Modderspruit and Karee Spruit.
5.9 Surface Water
5.9.1 Catchment Area and Characteristics
The Eastern Platinum Limited (EPL) Operations are situated within the jurisdiction of the Crocodile River West Catchment within the Crocodile West Marico Water Management Area. The Operations stretch over two Quaternary Catchments namely, the A21J and A21K. The source of the catchment is in the high lying topography formed by quartzites of the Magaliesburg, and the source extends onto the predominantly Arcadia soils derived from the Bushveld Igneous Complex. The Bushveld Igneous Complex forms the ridges and Rensburg soils in the drainage lines. Topographic slopes are steep close to the Magaliesburg and flatten appreciably further north away from the quartzite terrain.
The Modderspruit, Kareespruit, Maretlwane Spruit and their associated tributaries, drain from South to North through the property. The Kareespruit flows into the Crocodile River, which then also drains into the Rooikoppies Dam.
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Figure 5:6 Quaternary Catchment Areas – A21K and A 21J
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Figure 5:7 Quaternary Catchment Areas – A21K and A 21J
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5.9.2 Mean Annual Runoff The mean annual runoff (MAR) in the North West Province is reported to be very low. Average MAR as a percentage of the precipitation is 6% for the entire Province, which is below the average of 9% for Southern Africa. The MAR varies significantly from east to west ranging from approximately 7% in the eastern region to less than 1% in the far western region. The MAR for the Crocodile catchment is 209.5 X 106m3.
Areal extent (approximate), flood peaks (Kovaks Method) and runoffs for the different sub- catchments were calculated from where the stream originates upstream of the mine lease area, up to where the stream exits the mine lease area. Hydrological characteristics are as follows: -
Mean Annual Precipitation (MAP): 600 – 700 mm
Mean Annual Evaporation (MAE): 1 700 – 1 800 mm
MAR (5% of MAP): 30 – 35 mm
Detailed run-off studies were carried out for the storm water management plans of each business unit.
5.10 Heritage
Lonmin undertook a survey for the Heritage Resources in the Lonmin Marikana mine lease area in 2012.
The Lonmin Project Area falls within the Central Bankeveld which is a narrow strip of land which is situated between the northern bushveldt savannah and the centrally situated Highveld. The Central Bankeveld has its own unique heritage character which is dominated by numerous Tswana spheres of influence which are centuries-old and which is characterised by the remains of extensive stone walled settlements in all of the domains that were controlled by various Tswana chiefs whose origins date back to the seventeenth century. The following heritage and cultural resources are applicable to EPL1:
There are approximately four graveyards in the EPL mining Right Area. The graveyards include the formal Segwaelane, a grave yard containing more than a hundred graves at the edge of the EPL opencast; a graveyard containing thirty-five unmarked graves on the farm Middelkraal 466 JQ and a graveyard containing server graves and one headstone east of the Middelkraal dirt road; Clusters of stone walled sites; and A single stone walled site at Maroelakop, north of the Tailings dump.
The proposed chrome plant will be constructed on an area previously used by Lonmin in its operations i.e. the decommissioned surge dams. Due to the fact that the proposed footprint is already disturbed, no additional heritage assessments will be undertaken.
1 Pistorius, 2012, A Survey for Heritage Resources in the Lonmin Marikana Mine Lease Area in the Brits (Madibeng) and Rustenburg (Bafokeng) Districts in the North-West Province;
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5.11 Noise
Noise levels at the EPL MRA are expected to range from 40dBA (decibels) to 50dBA in the surrounding agricultural and residential area. In areas where mining-related activities are predominant, the noise level ranges between 60dBA to 70dBA. The main sources of noise at Lonmin Platinum Marikana Operations include:
Open pit mining activities; Ventilation fans (shafts); Main compressor house; Air compressors (shafts); Ore transfer points (shafts); Pumps (water distribution pumps, tailings pumps etc); Vehicular traffic; Opencast blasting; Crushing and screening; and Concentrator plants.
The affected communities are information settlements, formal residential areas, construction village and mine housing developments. Vibration and shock from blasting underground is highly reduced once the shaft has reached a depth of 30-40m. This impact is thus more relevant to the opencast operations and is it recognised that most residents live 500m or further away from the mine2.
5.12 Visual
The visual impact of the Lonmin Platinum Marikana Operations is determined in terms of:
Visibility; Sense of place; Visual quality; Character; Landscape compatibility; and Viewing Distance.
The proposed chrome plant will be located next to existing operational infrastructure and will not significantly alter the existing viewsheds. Therefore no additional visual impact assessments will be undertaken as part of the process although mitigation measures will be proposed as to reduce or mitigate any possible visual impacts.
5.13 Socio-economic3
The North West Province’s economy is derived from a variety of sectors, of which mining and agriculture are the main contributors. The mining sector is the lead supplier to the Province’s economy both financially and by its labour absorption capacity. Madibeng Local Municipality,
2 SEF, 2012. Eastern Platinum Mine Final Environmental Impact Assessment and Environmental Management Programme. 3 Madibeng Local Municipality, 2015. Spatial Development Framework.
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in particular Brits Town is a more formal urban area which has vibrant economic nodes. The Municipality area of Madibeng is characterized by a various economy, including vibrant agriculture, mining, and manufacturing as well as tourism sectors. Nonetheless, these sectors at present contribute a huge percentage to the total Gross Geographic Product (GGP), they are capable and have potential to encourage and accommodate economic growth and development. Madibeng is the world’s third largest chrome producer and includes the richest Platinum Group Metals Reserve (situated on the Merensky Reef). Manufacturing is the dominant sector, with motor industry related activities predominant.
The Spatial Development Framework of Madibeng Local Municipality was developed in line with the Municipal Planning and Performance Management Regulations of 2001 in accordance of Municipal Systems Act of 2000 (Act 32 of 2000). The Madibeng Local Municipality(NW 372) is situated in the North West Province and cover over an area of about 3 814 km². The Madibeng Local Municipality comprises of the following main towns Brits, Hartbeespoort, Skeerpoort area, 9000 farm portions as well as 43 villages. The Madibeng Local Municipality is demarcated into 41 Wards. The population of Madibeng is estimated by the 2011 population census to be at 477 381. Madibeng Local Municipality is located or situated on the Northern part of North West Province and one (1) of the five (5) local municipalities within the Bojanala District Municipality.
In terms of the Municipal Systems Act, 2000 all municipalities must prepare a Spatial Development Framework (SDF) as a core component of the Integrated Development Plan (IDP). Of vital importance, Chapter 5 of the MSA (Act 32 of 2000) provides for the preparation of IDPs:
Section 24(1) requires that municipalities should align their planning with national and provincial planning, as well as those of affected municipalities; Section 26(e) lists an SDF as a core component of an IDP and requires that the SDF provides basic guidelines for a municipal land use management system.
With regard to human settlement provision, the National Housing Act provides for the facilitation of a sustainable housing development process and lays down general principles applicable to housing development. The Act provides the following prescriptions concerning housing provision:
Prioritise the housing needs of the poor; Provide as wide a choice of housing and tenure options as is reasonably possible; Be economically, fiscally, socially and financially affordable and sustainable; Be based on integrated development planning; Consider and address the impact on the environment; Socially and economically viable communities; Safe and healthy living conditions; Racial, social, economic and physical integration in urban and rural areas; Effective functioning of the housing market and level playing fields; and Higher densities and the economical utilisation of land and services.
In 2010, government commissioned the National Planning Commission to develop the National Development Plan, 2030 which is regarded as a blueprint policy framework that guide government on the development of the country. The National Development Plan, 2030 provides a new scope of focus for planning authorities, in that its focus areas that affect spatial planning include the following:
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Creating jobs and livelihoods; Expanding infrastructure; Transition to a low carbon economy; Transforming urban and rural spaces; Education and training; and Provide adequate health care.
The NDP vision 2030 identifies the following investments as key priorities:
Upgrading of informal settlements; Provision and renewal of existing public transport infrastructure and public transport systems; Development of a freight corridor between Durban and Gauteng; Development of new water schemes for urban and industrial centres; Construction of infrastructure for importing liquefied natural gas; Construction of infrastructure for accelerated exploration in an effort to find more gas feedstock’s; and Addressing the challenge of energy availability through the use of renewable energy and importing electricity from the region.
5.13.1 Population Density
According to Stats SA 2011 Madibeng Local Municipality has population of 477 381 people growth rate of 3, 2% from 2001 to 2011. Therefore, it is tabulated that the Municipality has a population density of 124 persons/km2.
5.13.2 Age and Gender Distribution
Statistics indicates that most population within the municipality is infants younger than four years of age as well as youth and adults ranging between 20 and 34 years of age. The gender figure below created from census 2011 data reveals that on average, the majority of individuals in Madibeng are of the male sex group.
5.13.3 Household Income
The mining sector in the area is one of the highest employment creators. Some of the world's richest platinum deposits and the largest chromate reserves are found in Madibeng local municipality. Other mining products include ferrochrome, stone and granite quarries, silica sand and vanadium pentoxide.
10% of the population has no income. 20% of the population earn between R 19 000 to R 38 000 per month. 10% of the population earn between R 38 000 and R 77 000 per month and 9% of the population between R77 000 and R 154 000 per month.
5.13.4 Language
The Madibeng Local Municipality is dominated by Setswana speaking people. This is attributed to the fact that the North West province is dominated by Batswana due to its history and proximity to the country of Botswana. From a local context and lesser extent, there are traces of Afrikaans, Xitsonga, Sepedi and Sesotho speaking people which each of them contribute less than 15%.
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6 POSSIBLE ENVIRONMENTAL IMPACTS
The following chapter provides identification and description of potential environmental impacts to be caused by the proposed development of the.
The following specialist studies have been identified as to undertake the Impact Assessment inclusive of the Construction, Operation and Closure phases of the project confirming the impacts, the best suitable alternatives and mitigation measures for the proposed accommodation facility:
Soils, Land Use and Land Capability Assessment; Freshwater and Terrestrial Ecological Assessment; Hydrogeological (Groundwater) Impact Assessment; Hydrological (Surface Water) Impact Assessment; Noise Impact Assessment; Socio-economic Impact Assessment; and Financial Provision
6.1 Construction Phase
During the construction phase of the project, the following aspects and impacts may occur:
• Habitat destruction or habitat fragmentation - Clearance of vegetation outside of the already disturbed footprint area; • Compaction of soils, soil erosion and sedimentation; • Noise generated by delivery and construction vehicles; • Fugitive dust generated by delivery and construction vehicles; • Oil leaks and spills from moving construction vehicles – impacts on soils, surface water and groundwater; • Sewage effluent generated by construction workers on site; • Stormwater management around laydown and construction areas – impact on water quality and quantity; • Waste generation (general and hazardous waste) 6.2 Operational Phase
During the operational phase of the project, the following aspects and impacts may occur:
Generation of domestic and hazardous waste; Generation of sewage effluent; Vehicular movement in and out from the site – generation of noise and dust; Social impacts associated with people on site i.e impact of human activities, skills development, jobs, etc; Visual Impact - Night time light pollution; Inadequate Stormwater management
6.3 Decommissioning and Closure Phase
During the decommissioning and closure phase, the following aspects and impacts may occur:
Generation of demolition and building rubble; Generation of noise through vehicular movement on site; Generation of fugitive dust through vehicular movement on site;
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Oil leaks and spills from moving construction vehicles - impacts on soils, surface water and groundwater; Compaction of soils due to vehicular movement; Impact of the establishment of Alien and Invasive Plant Species on disturbed and rehabilitated areas. Rehabilitated land could provide opportunities for other sectors. Remediation will prevent any environmental degradation or damage.
6.4 Cumulative Impacts
According to the NEMA EIA Regulations, 2010, “cumulative impact, in relation to an activity means the impact of an activity that in itself may not be significant, but may become significant when added to the existing and potential impacts eventuating from similar or diverse activities or undertakings in the area.”
DEA (2004) assigns a temporal and spatial association to the description, noting that development has in the past not accounted for the accumulation of impacts when considered in combination with other activities. This has resulted in the need for Cumulative Impact Assessment (CIA), (also referred to as Cumulative Effects Assessment), which address impacts on a local, regional and sometimes global scale.
DEAT (2004) describes principles of cumulative effects assessment which, amongst others, are the aggregate of past, present and reasonably foreseeable future actions; the total effect, including both direct and indirect effects, on a particular resource, ecosystem, and human community of all actions taken; and the focusing of analyses on meaningful environmental receptors.
With relevance to the proposed expansion of EPL Chrome Plant, cumulative impacts will be considered by each specialist in context of each discipline.
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7 IMPACT ASSESSMENT METHODOLOGY
7.1 Impact Assessment Methodology to be used
The environmental impact assessment forms the basis for the EMP. The main purpose of the EMP is to ensure that effective management measures are tabled, that will ensure through the practical implementation thereof that all potential impacts are either avoided, successfully managed or mitigated to such an extent that it does not lead to environmental degradation or contamination.
The significance of the identified impacts will be determined using an accepted methodology from the Department of Environmental Affairs and Tourism Guideline document on EIA Regulations, April 1998. As with all impact methodologies, the impact is defined in a semi- quantitative way and will be assessed according to methodology prescribed in the following section.
Table 7.1: Scale utilised for the evaluation of the Environmental Risk Ratings
Evaluation Rating Scale Description / criteria Component Bio-physical and/or social functions and/or processes might be severely 10 Very high altered.
Bio-physical and/or social functions and/or processes might be considerably 8 High MAGNITUDE of altered. negative impact Bio-physical and/or social functions and/or processes might be notably 6 Medium (at the indicated altered. spatial scale) Bio-physical and/or social functions and/or processes might be slightly 4 Low altered. Bio-physical and/or social functions and/or processes might be negligibly 2 Very low altered. 0 Zero Bio-physical and/or social functions and/or processes will remain unaltered. Positive: Bio-physical and/or social functions and/or processes might be 10 Very high substantially enhanced. Positive: Bio-physical and/or social functions and/or processes might be 8 High considerably enhanced. MAGNITUDE of Positive: Bio-physical and/or social functions and/or processes might be 6 Medium POSITIVE IMPACT notably enhanced. (at the indicated Positive: Bio-physical and/or social functions and/or processes might be 4 Low spatial scale) slightly enhanced. Positive: Bio-physical and/or social functions and/or processes might be 2 Very low negligibly enhanced. Positive: Bio-physical and/or social functions and/or processes will remain 0 Zero unaltered. 5 Permanent Impact in perpetuity. – 4 Long term Impact ceases after operational phase/life of the activity > 60 years. Impact might occur during the operational phase/life of the activity – 60 DURATION 3 Medium term years. 2 Short term Impact might occur during the construction phase - < 3 years. 1 Immediate Instant impact. 5 International Beyond the National boundaries. 4 National Beyond provincial boundaries, but within National boundaries. EXTENT Beyond 5 km of the Mothae Diamond Mine and within the provincial (or spatial 3 Regional boundaries. scale/influence of 2 Local Within a 5 km radius of the Mothae Diamond Mine. impact) 1 Site-specific On site or within 100 meters of the site boundaries. 0 None Zero extent. 5 Definite Definite loss of irreplaceable resources. IRREPLACEABLE 4 High potential High potential for loss of irreplaceable resources. loss of resources 3 Moderate potential Moderate potential for loss of irreplaceable resources. 2 Low potential Low potential for loss of irreplaceable resources.
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1 Very low potential Very low potential for loss of irreplaceable resources. 0 None Zero potential. 5 Irreversible Impact cannot be reversed. 4 Low irreversibility Low potential that impact might be reversed. REVERSIBILITY of 3 Moderate reversibility Moderate potential that impact might be reversed. impact 2 High reversibility High potential that impact might be reversed. 1 Reversible Impact will be reversible. 0 No impact No impact. 5 Definite >95% chance of the potential impact occurring. 4 High probability 75% - 95% chance of the potential impact occurring. PROBABILITY (of 3 Medium probability 25% - 75% chance of the potential impact occurring occurrence) 2 Low probability 5% - 25% chance of the potential impact occurring. 1 Improbable <5% chance of the potential impact occurring. 0 No probability Zero probability. Evaluation Rating scale and description / criteria Component High: The activity is one of several similar past, present or future activities in the same geographical area, and might contribute to a very significant combined impact on the natural, cultural, and/or socio-economic resources of local, regional or national concern. CUMULATIVE Medium: The activity is one of a few similar past, present or future activities in the same geographical area, and impacts might have a combined impact of moderate significance on the natural, cultural, and/or socio-economic resources of local, regional or national concern. Low: The activity is localised and might have a negligible cumulative impact. None: No cumulative impact on the environment.
Once the Environmental Risk Ratings have been evaluated for each potential environmental impact, the Significance Score of each potential environmental impact is calculated by using the following formula:
SS (Significance Score) = (magnitude + duration + extent + irreplaceable + reversibility) x probability.
The maximum Significance Score value is 150.
The Significance Score is then used to rate the Environmental Significance of each potential environmental impact as per Table 8.2 below. The Environmental Significance rating process is completed for all identified potential environmental impacts both before and after implementation of the recommended mitigation measures.
Table 7.2: Scale utilised for the evaluation of the Environmental Risk Ratings
Significance Environmental Description / criteria Score Significance An impact of very high significance will mean that the project cannot proceed, and 125 – 150 Very high (VH) that impacts are irreversible, regardless of available mitigation options. An impact of high significance which could influence a decision about whether or 100 – 124 High (H) not to proceed with the proposed project, regardless of available mitigation options. If left unmanaged, an impact of medium-high significance could influence a decision Medium-high 75 – 99 about whether or not to proceed with a proposed project. Mitigation options should (MH) be relooked at. If left unmanaged, an impact of moderate significance could influence a decision 40 – 74 Medium (M) about whether or not to proceed with a proposed project.
An impact of low is likely to contribute to positive decisions about whether or not to <40 Low (L) proceed with the project. It will have little real effect and is unlikely to have an influence on project design or alternative motivation.
Positive impact A positive impact is likely to result in a positive consequence/effect, and is likely to + (+) contribute to positive decisions about whether or not to proceed with the project.
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8 PLAN OF STUDY FOR ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
Due to the development of the Expansion of Chrome Plant to be undertaken on an existing disturbed area the following specialist studies have been identified as to be undertaken in support of the Impact Assessment. The Impact Assessment will take into account all possible activities to be undertaken during the Construction, Operation and Closure phases of the project confirming the impacts, the best suitable alternatives and mitigation measures for the proposed accommodation facility:
Soils, Land Use and Land Capability Assessment; Freshwater and Terrestrial Ecological Assessment; Hydrogeological (Groundwater) Impact Assessment; Hydrological (Surface Water) Impact Assessment; Air Quality Specialist Study; Review of the Heritage Study; Noise Impact Assessment; and Closure Financial Provision
Table 8.1 below provide the Terms of Reference for the specialist studies.
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Table 8.1: Terms of Reference for Specialist Studies / Plan of Study for EIA
Specialist Study Terms of Reference Undertake a preliminary survey and identification of noise measuring points All noise measurements will be done in the vicinity of the project areas and noise receptors; Noise survey at the identified measuring sites – Ambient noise measurements; Noise Assessment Calculation of noise propagation; Analysing of results taking into account possible sensitive receptors in the area; Undertake an impact assessment using an approved impact assessment methodology; Write a report in support of the impact assessment Undertake a desktop study; Field Assessment; o o identify and consider all sensitive landscapes including rocky ridges, wetlands and any other ecologically important features, if present Characterise the terrestrial habitat integrity; Terrestrial Ecological Habitat o determine the environmental impacts that the construction of the proposed operation of the chrome plan might have Integrity Investigation on the terrestrial ecology as well as potential impacts on the ecology due to activities related to the proposed activities and to develop mitigation and management measures for all phases of the development; Determine Present Ecological State (PES) Determine the Ecological Importance and Sensitivity (EIS); Provide a detailed impact assessment of all identified significant risks, including cumulative impacts on ecological assemblages in the region; Give recommendations on the management and mitigation measures. A baseline Soil and Land Capability Assessment will be conducted within the proposed development area of approximately ten hectares (10 ha); o Review and verify current land uses within the vicinity of the study area; o Record local topographic features of the landscape, as estimated slope gradient; o Identify master and diagnostic horizons to a depth of refusal or within 1.5m of ground surface; o Soil and Land Capability Describe potential soil limitations/restrictions to land capability; o Classify identified soils into soil forms according to the Taxonomic Soil Classification System for South Africa (1991); Assessment o Assess spatial distribution of various soil types within the study area; and o Compile soil and land capability maps under current on-site conditions based on the field assessment data. An Impact assessment will be carried out to identify and assess the significance of potential impacts of the proposed development activities on the land capability of the investigated area; and A baseline Land Capability report will be compiled, where key mitigation and management measures will be provided to alleviate the identified impacts.
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Specialist Study Terms of Reference Undertake a desktop study; Field Assessment - Investigate freshwater resources within the study area; Delineate of those freshwater resources within 500m from the proposed project development area; Characterise the: o Freshwater Ecological Assessment Present Ecological State (PES); o Ecological Importance; o Sensitivity (EIS) of the freshwater ecological environment and to identify ecosystems and biological assemblages at risk. Undertake an impact assessment using an approved impact assessment methodology; Write a report in support of the impact assessment and water use licence application. Undertake a desktop investigation; o Investigate existing documentation pertaining to stormwater management from the bordering infrastructure; o Delineate the applicable catchment boundaries; o Take into account any future development areas for the site and areas that may border the development; Undertake a detailed survey of the area; Calculate the following: o Expected run-off figures for the area – 1:50 and 1:100 year flood events; Hydrological o Determine the 1:100 year flood line for the area; Develop a Conceptual Storm Water Management Plan; Develop a static water balance for the structures associated with the storm water management plan; Develop the Conceptual Designs for clean and dirty water separation and containment facilities in support of the Water Use Licence Application; Undertake an impact assessment using an approved impact assessment methodology; Write a report in support of the impact assessment and water use licence application. Phase A: - Hydrogeological Baseline Assessment Desk study and review of existing groundwater baseline information and historical reports. Hydrogeology Site visit and hydrocensus user survey to evaluate the existing surface and groundwater uses, community borehole locations and depths, regional water levels, abstraction volumes, local springs as well as environmental receptors in the vicinity of the proposed construction camp alternatives
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Specialist Study Terms of Reference Sampling of existing boreholes and surface water bodies according to best practise guidelines and analyses of twelve (12) water samples to determine the macro and micro inorganic chemistry and hydraulic connections based on hydrochemistry (analyses at SANAS accredited laboratory). Assess the structural geology and geometry of the aquifer systems with respect to hydraulic interactions in the vicinity of the mining operations Data interpretation aiding in aquifer classification and vulnerability ratings. Development of a scientifically defendable hydrochemical baseline. Compilation of geological, hydrogeological and hydro-chemical GIS maps of the aquifer system, indicating spatial distribution of hydro-chemical analysis. Phase B – Impact Assessment and Reporting Compilation of a hydrogeological specialist report with conclusions and recommendations on the following aspects: o Fatal flaw and gap analyses. o Site baseline characterisation. o Aquifer classification and vulnerability. o Field work summary and interpretation. o Environmental impact assessment and risk matrix. o Mitigation and management measures. o Groundwater and surface water monitoring protocol. Compilation of a surface water and groundwater monitoring protocol. The existing 2012 A Survey for Heritage Resources in the Lonmin Marikana Mine Lease Area in the Brits (Madibeng) and Rustenburg Heritage • (Bafokeng) Districts in the North-West Province will be used as the basis for the Impact Assessment. Existing Air Quality data will be used in the assessment of the proposed impacts associated with the proposed expansion of EPL Air Quality • Chrome Plant. An updated Financial Provision document will be compiled as to allow for the calculation of the closure costs associated with the Financial Provision • proposed new Chrome Plant.
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9 PUBLIC PARTICIPATION PROCESS
The objectives of the Stakeholder Engagement process include the following:
To provide opportunities for the public and stakeholders a better understanding of the proposed project and its possible impacts; Provide an opportunity as to draw knowledge and experience of the stakeholders as to improve planning and decision-making; To build relationships with the public and stakeholders that lead to mutual support and confidence; and To enable Lonmin Plc – EPL to meet its legal and regulatory responsibilities.
At a high level, the Project EIA process is undertaken in five key phases, in accordance with the EIA Regulations (GNR. 982) of December 2014, as amended.
Application Phase – identify listed activities that are triggered by the Project and submit an application for EA to the competent authority.
Scoping Phase - identify interactions of project activities and environmental and social resources to determine which should be included in the scope of the impact assessment.
Environmental Impact Reporting Phase - the characteristics of the potential effects of project activities on bio-physical and social resources and features are evaluated and quantified to determine potential impact significance (or importance) taking into account the sensitivity of the particular resource or receptor. This phase also includes the identification of mitigation/management measures and the development of an Environmental Management Programme.
Competent Authority Decision – the decision on the Project will be distributed to all project interested and affected parties and informed of the appeal process.
The public consultation activities undertaken during the EIA process is described under each phase. The Project is currently at the Scoping Phase.
9.1 Notification of I&AP’s
In accordance to the EIA Regulations, the applicant / environmental assessment practitioner (EAP) must give notice to all potential I&APs of the application. AvD Environmental notified I&AP’s by means of the following methods:
9.1.1 Notification Letters
Notification letters were sent to all stakeholders available on the existing stakeholder database. These stakeholders were invited to register as Interested and Affected Parties for the proposed project going forward.
These notification letters were accompanied by a Background Information Document explaining the project as well as the legislative processes. Interested and Affected Parties whom have registered were notified in writing of all available documentation once placed in the public domain as well as the required response periods. In accordance to the regulatory requirements, written notice was given to: Land Owners and occupiers adjacent to and within 100 metres of the boundary of the site as well as alternative sites being considered;
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The municipal councilor of the ward in which the site as well as alternative sites being considered are situated and any organisation of ratepayers that represents the community in the area; The municipality which has jurisdiction in the area (both Local Municipality and District Municipality); and Any organ of state having jurisdiction in respect of any aspect as the activity.
9.1.2 Site Notices
The placement of Site Notices is a requirement in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) and the Publication of Public Participation Guide, (GN 35769 dated 10 October 2012. Based on the EIA Regulations, the minimum size for the notice boards must be 60cm by 42cm and must display the required information in lettering and in a format as may be determined by the Competent Authority.
9.1.3 Newspaper Advertisement
According to the EIA Regulations, the advertisement should indicate the duration of a commenting period. In accordance with the minimum requirements of the promotion of Administrative Justice Act, 2000 (Act No 3 of 2000) (PAJA), all interested and affected parties must be provided with a reasonable opportunity to make representations. This reasonable period is 30 (thirty) days. Should there be a public meeting, then the notice for this meeting should be 14 (fourteen) days.
9.2 Stakeholder Engagement during Scoping and EIA Phase
Before submission of the Final Scoping and Environmental Impact Assessment/ Environmental Management Plan Reports, the competent authority regulates that an allowance must be made to give registered interested and affected parties access to, and an opportunity to comment on the reports in writing. A registered interested and affected party is entitled to comment on all written submissions made to the competent authority by the applicant or the EAP managing the application, and to bring to the attention of the competent authority any issues which the registered interested and affected party believe may be of significance to the consideration of the application. These comments were submitted within the specified timeframes. The Departments reference number is quoted in all correspondence.
Only if there are substantial changes to the Draft Scoping and Environmental Impact Assessment/ Environmental Management Plan Reports should it be made available to the registered interested and affected parties prior to submission otherwise it may be submitted together with the Issues and Response Report to the competent authority.
The Draft Reports were placed at the following placing for public viewing and commenting:
Table 9.1: Locations of the Draft Scoping and Draft Environmental Impact Assessment Reports
Public Place Locality Physical Address Contact Details 317 Erf Marikana Public Library Marikana 014 572 3611 Marikana 18 Murray Avenue Brits Post Office Brits 012 252 3121 Brits Eastern Platinum Hannelie Ryan Lonmin EPL Offices EPL Marikana 014 571 2399
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Public Place Locality Physical Address Contact Details Operations Matshediso Matshedi Lonmin EPL Hostels 014 571 4445 Bapong Community Health Next to Bapo Primary School Bapong 012 245 1237 Centre Skoolplaas Street, Bapong Stand 0864H Segwaelane Clinic Brits 012 245 1162 Segwaelane, Brits Unit 3698 Offices of Alta van Dyk Centurion 4 Garcia Peak Road 012 940 9457 Environmental Consultants Midlands Estate Website: www.altavandykenvironmental.co.za
Specialist studies in support of the EIA and EMP will be annexed to the Draft EIA and EMP as well as the Final EIA and EMP and will be included in the documents set out in the public domain during the commenting period.
Refer to Annexure A for the Stakeholder Engagement Report.
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10 CONCLUSION
The aim of the Scoping Report is to identify the possible environmental, social and economic risks and impacts which might be associated with the construction of the Chrome Plant at EPL. The Scoping Report is also the start of the Public Participation Process where the public gets the opportunity to register as Interested and Affected Parties to receive further information about the project. It is the stage in the process where the Terms of References for specialist studies to be undertaken is determined as part of the Environmental Impact Study. At this stage there are no fatal flaws identified to prevent the project from continuing. Potential impacts have been identified and these will be assessed in the Impact Assessment Phase.
The main purpose of scoping is to focus the environmental assessment important issues and to ensure that the significant issues are addressed and reasonable alternatives examined.
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11 UNDERTAKING BY EAP
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12 REFERENCES
Agreenco Environmental Projects, July 2015, Biodiversity Action and Management Plan Marikana Divisions
Constitution of the Republic of South Africa (1996).
E-TEK Consulting, January 2018, Specialist Report: Surface Water Part of the Environmental Assessment and Authorisation Process for the proposed construction of a new Chrome Plant
Highlands Hydrology, November 2012, Conceptual Stormwater Management Plan for EPL- EPC Concentrator
Madibeng Local Municipality, 2015. Spatial Development Framework. http://www.madibeng.gov.za/wp-content/uploads/2015/07/Madibeng-SDF_June-10.pdf> date accessed 29 January 2018.
Mineral and Petroleum Resources Development Act (No 28 of 2002).
National Environmental Management Act (No 107 of 1998) and associated EIA Regulations 983, R984 and R985 (2017 as amended)
National Environmental Management: Waste Act, 2008 (No. 59 of 2008) and associated Regulations Government Notice 718, Category A and B.
National Environment Management: Air Quality Act (No 39 of 2008) and associated Regulation GN248.
National Environmental Management: Biodiversity Act, 2008 (No. 10 of 2004) and associated Regulations Government Notice 151 of 2010.
National Heritage Resources Act (No 25 of 1999).
National Water Act (No. 36 of 1998).
Pistorius, Julius CC; A Survey for Heritage Resources in the Lonmin Marikana Mine Lease Area in the Brits (Madibeng) and Rustenburg (Bafokeng) Districts in the North-West Province; October 2012.
SEF, 2012: Eastern Platinum Mine Final Environmental Impact Assessment and Environmental Management Programme
World Weather Online, www.worldweatheronline.com
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